Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor

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12/02/2005 FinCEN Releases 9th SAR Activity Review
Issue 9 of The SAR Activity Review includes an analysis of SAR reporting by the securities and futures industries, and notes that the number of filings involving identity theft is increasing, just as that crime is increasing.  Some SARs were filed concerning accounts that were funded but remained idle for long periods, followed by sudden liquidation activity, particularly where funds were sent outside the U.S. The Review notes that “lack of activity in an investment account may serve as a red flag to broker-dealers.”  In the section of the Review on tips for completing SARs, FinCEN notes that even insignificant errors in SARs should be corrected.  What seems insignificant or inconsequential to a filer may still be important to law enforcement.  If the SAR is a correction of a previously filed SAR, the item indicating that is to be checked and “a new SAR-SF must be completed in its entirety.”  Corrected aspects are to be detailed in the narrative portion of the form. The SAR Activity Review will be discussed in detail in the January 2006 issue of the Monitor. 

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