Money Laundering: Extent of Money Laundering through Credit Cards Is Unknown Page: 57 of 61
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Appendix V
Review of SAR Database on Potential Money
Laundering through Credit CardsMost SARs Related to
BSA/Structuring/Money
Laundering ViolationsMost SARs Were Isolated
CasesCash Structuring Fairly
Common in SARs FiledFinCEN provided the following breakdown on the 499 SARs that were
identified in the review:
* Financial institutions filed 488 (97.7 percent) of the SARs for
BSA/structuring/money laundering violations;
* Eight SARs that were filed by financial institutions cited credit card
fraud as the primary violation;
* Two SARs that were filed by financial institutions cited debit card fraud
as the primary violation;
* One SAR that was filed by a financial institution cited
defalcation/embezzlement as the primary violation.
FinCEN found that 134 financial institutions, including 1 foreign bank
licensed to conduct business in the United States, filed the 499 SARs. The
amount of money involved in the violations ranged from $0 to $9.76 million.
Seven of the SARs filed by these institutions were for amounts in excess of
$1 million. Seventy of the 499 SARs (14 percent) were referred directly to
law enforcement by the financial institution, in addition to being filed with
FinCEN. Of these, 39 were reported to federal agencies and 31 to state or
local authorities.
FinCEN found only a few cases in which 2 or more SARs were filed on the
same individual or business. This indicated that activity reported on most
of the SARs was considered "an isolated incidence" by the reporting banks,
according to FinCEN. One exception involved 6 SARs that were filed in
early 2001 on four suspects, which revealed that check payments credited
to these individuals' credit card accounts were made by a fifth individual.
This activity indicates that the subjects had ties to the person making the
payments, according to FinCEN. This individual had been indicted on
charges of money laundering, contraband cigarette smuggling, and
visa/immigration fraud charges. This was the only incidence within the 499
SARs where a group of individuals could be linked to one another.
FinCEN found that 115 of the 499 SARs (or 23 percent) described cash
structuring activity in the narratives. Typically, the SARs described
customers attempting to make multiple deposits in amounts under $10,000,GAO-02-670 Money Laundering
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United States. General Accounting Office. Money Laundering: Extent of Money Laundering through Credit Cards Is Unknown, report, July 22, 2002; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc294144/m1/57/: accessed April 18, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.