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The report can start with any employee of a financial services institution. The employees are trained to be alert for suspicious activity, such as situations where people are trying to wire money out of the country without identification, or activity by someone with no job who starts depositing large amounts of cash into an account.
A suspicious activity report is a report of suspicious activity that may either be a terrorist act, a criminal act, or a non-criminal act considered a precursor to either a terrorist act or criminal act. A SAR may be filed by law enforcement, public safety personnel, owners of critical infrastructure or the general public.
Suspicious activity is defined in the ISE-SAR Functional Standard (ISE-SAR FS) Version 1.5 [6] as "observed behavior reasonably indicative of pre-operational planning related to terrorism or other criminal activity." The NSI is a behavior-focused approach to identifying suspicious activity.
For the year 2021, FinCEN received 1,137,451 Suspicious Activity Reports (SARs), which include both traditional financial institutions and cryptocurrency trading entities. Within this category, there were reports of 7,914 suspicious cyber events and 284,989 potential money laundering activities.
A report by the BBC suggests that the FinCen Files reveal that the United Kingdom bank HSBC was involved in numerous illegal money transfers. [39] At the time, HSBC was subject to a deferred prosecution agreement for the laundering of $881 million on behalf of the Sinaloa and Norte del Valle cartels . [ 2 ]
The USA PATRIOT Act was passed by the United States Congress in 2001 as a response to the September 11 attacks in 2001. It has ten titles, with the third title ("Title III: International Money Laundering Abatement and Financial Anti-Terrorism Act of 2001") written to prevent, detect, and prosecute international money laundering and the financing of terrorism.
In 2022 BitMEX, a cryptocurrency exchange trading platform failed to maintain a compliant anti-money laundering and customer identification program, and to report suspicious activity. [13] [14] BitMEX received a civil monetary penalty of $100 million from FinCEN for violating the Bank Secrecy Act (BSA).
When these activities are discovered, casino staff are required to file a Suspicious Activity Report (SAR) to report the suspicious activities. Because there are many types of suspicious activities, it is required that casino personnel receive Title 31 training to avoid penalty and remain compliant.