The FinCEN Files – NewLink's Perspective
New Link Consulting have published their perspectives of the FinCEN files in the following blog post:
"Over 2,100 Suspicious Activity Reports (‘SARs’) that were filed with the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) between 2011 and 2017, have been leaked to BuzzFeed News and investigated by a team of reporters from the International Consortium of Investigative Journalists (‘ICIJ’). There has been no question regarding the authenticity of the documents. The ICIJ is drip-feeding the results of its investigations, which have involved many major global banks, so we can expect more revelations over the coming weeks and maybe even months. The documents in the FinCEN files cover about $2tn of transactions and they are only a tiny proportion of the SARs submitted over the period."
In this blog we do not propose to look into the rights and wrongs of the leak itself and the daily news stories that have followed. We recognise that many banks have made huge investments in the prevention of financial crime and we clearly observe the commitment, even passion, of many financial crime practitioners to identify and root out the bad actors. Rather, we would like to focus attention upon the practical response banks should be considering now."