The “FinCEN Files” leak has presented all of us with an opportunity to change. It informed the public of something we all knew: Anti-money laundering (AML) efforts are failing. Anyone who perceives otherwise is in denial, and that will hinder the implementation of much-needed improvements.
When I examined some of the leaked SARs, I was struck by the lack of suspicion of a crime presented within the narrative and the failure to ask the customer to explain the unusual nature of some transactions. It was evident to me there remains a misunderstanding with “tipping off” a customer or third party regarding the filing of SARs.
