Anti-Money Laundering Compliance: SAR Filings Show Increases for Suspected Check Fraud

January 26, 2010

Filings of Suspected Mortgage Fraud Leveled Off

On January 22, 2010, the Financial Crimes Enforcement Network (FinCEN) reported that filings of Suspicious Activity Reports (SARs) during the first six months of 2009 for check fraud increased for all of the industries required to file SARs under the Bank Secrecy Act (BSA), as compared to the first six months of 2008.

For example, SAR filings by depository institutions increased by 19% for check fraud and by 36% for instances of suspected counterfeit checks. Similarly, BSA-covered entities in the securities, futures, and insurance industries increased their filings of SARs by 19% for check fraud. Money services businesses (MSBs) increased their SAR filings for fraud involving Traveler’s Checks by 76%. Reports filed by casinos of check fraud rose by 18% while reports for unusual use of checks rose by 16%.

Notably, the filings of SARs for mortgage fraud, which saw a dramatic increase in 2008, began to stabilize in 2009. The filings of SARs by depositary institutions identifying mortgage fraud increased only 1% during the first six months of 2009 as compared to 2008. By comparison, during the first six months of 2008, the filings of SARs increased nearly 40% as compared to 2007.

Other notable SAR filing figures released by FinCEN included:

Wire fraud

  • Depository institutions increased their filing of SARs by 25%.
  • BSA-covered entities in the securities, futures, and insurance industries increased their filings of SARs by 35%.

Computer fraud

  • Depository institutions increased their filing of SARs for computer intrusion by 75%.
  • BSA-covered entities in the securities, futures, and insurance industries increased their filings of SARs by 41%.

McGuireWoods’ Government, Regulatory and Criminal Investigations Department has attorneys with extensive experience with AML compliance and investigation matters, as well as the defense of white collar criminal investigations. The most valuable weapons a corporation and its officers and directors have against potential AML issues are preparedness, responsiveness and the deployment of a robust compliance program designed to detect and prevent money laundering.

McGuireWoods is prepared to assist with everything from defending investigations to conducting money laundering risk assessments, audits and internal investigations, and designing and helping to implement overall and AML-specific corporate compliance programs and training.

For more information about our capabilities in this or any other area, please contact the authors.

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