FinCEN, a bureau of the Department of the Treasury (Treasury), to further its efforts against money laundering and terrorist financing, and as required by 31 U.S.C. § 5318(n), is proposing to issue regulations that would require certain banks and money transmitters to report to FinCEN transmittal orders associated with certain cross-border electronic transmittals of funds (CBETFs). FinCEN is also proposing to require an annual filing with FinCEN by all banks of a list of taxpayer identification numbers of accountholders who transmitted or received a CBETF.
This report details key findings of the Financial Crimes Enforcement Network’s (FinCEN) assessment of Suspicious Activity Reports (SARs) filed from May 2, 2007, through April 30, 2008, by insurance companies and includes some preliminary observations about SARs filed from May 2008 through October 2009. It compares the results through April 2008 with a similar study of the first year of required reporting by segments of the insurance industry (May 2, 2006, through May 1, 2007). FinCEN analyzed insurance filings to identify typologies, patterns, and trends related to filing volume, filer location, subject details, characterizations of suspicious activities, insurance products, and other relevant information. Analysis includes summaries of SAR narratives identifying reported money laundering risks and vulnerabilities. In identifying potential trends, FinCEN reached out to representatives of the Bank Secrecy Act Advisory Group (BSAAG) to better understand what the industry is seeing with regard to these trends. That information is summarized in the Significant Findings section.