Following on from a study of terrorism-related suspicious activity reports (SARs), the Financial Crimes Enforcement Network (FinCEN) and the Federal Reserve Board recently proposed an adjustment to the mandatory reporting of low-value international wire transfers. Presently, banks and other regulated businesses in the United States must report and store records of all transactions, both domestic and international, with a value in excess of $3,000. The proposal requests a change that will compel firms to report all international wire transfers with a value in excess of $250.
This is not a figure plucked out of the air: It is based upon analysis that indicates some terrorists operating outside of the United States are being funded through donations with sums considerably lower than $3,000. Thus, the proposal seeks to present challenges and obstacles to those seeking to fund terrorist activity using U.S. dollars and assist agents engaged in the investigation of terrorist activities.
