Even though the “FinCEN Files” provide evidence confirming banks and regulated firms comply with legal requirements to report suspicious transactions, the individual reports themselves suggest there are a lot of faults and failings within the anti-money laundering (AML) frameworks in these banks/firms. In multiple instances, suspicious activity reports (SARs) are filed after a regulatory inquiry or upon discovery of information within media reports.
In one example from the leaks, a bank processed in excess of $1 billion of transactions for a client before closing the relationship. It was some time after the closure of the accounts that the bank came upon information suggesting the client, a corporate entity, was owned by a man who has spent more than 20 years on the FBI’s Ten Most Wanted Fugitives list. Subsequently, the bank reported it was unable to establish ownership for the client company from the “Know Your Client” records held in London and New York.
