FinCEN FILES – UPDATE

How the FinCEN papers provide an opportunity to improve the SAR regimes

On 21 September, 5 St Andrews Hill Chambers in London published an article saying that the headlines will obviously focus on the amount of money involved and the details of particular prominent individuals, and that criticism is already being levelled at the banks for the way in which they have permitted these transactions to have taken place. It looks at problems with the SAR regimes, citing comments made by the Law Commission in the UK.  The article concludes that it is the lack of resources that prevents law enforcement from dealing with the global issue that money laundering represents.

https://www.5sah.co.uk/news-and-events/articles/2020-09-21/how-the-fincen-papers-provide-an-opportunity-to-improve-the-suspicious-activity-report-sars-regime

FinCEN Files: The art of evading sanctions

On 24 September, an article from Deutsche Welle reported that sanctions are popular means to frighten despots and enforce national interests – but the FinCEN files show that sanctions can be circumvented, often with the help of banks.

https://www.dw.com/en/fincen-files-the-art-of-evading-sanctions/a-55040214

One fix to the deluge of SAR

American Banker on 24 September suggests ending the US requirement to file SAR about otherwise legal (under state laws) cannabis businesses.  The opinion piece says that filing SAR on marijuana-related businesses is a relic of the “Reefer Madness” mentality whose time has long since expired.

https://www.americanbanker.com/opinion/one-fix-to-the-deluge-of-suspicious-activity-reports

The FinCEN Files – live aggregated news

FinCEN leak sheds light on the hidden money flows of Putin’s Russia

https://www.rferl.org/a/major-questions-fincen-leak-sheds-light-on-the-hidden-money-flows-of-putin-s-russia/30855925.html

Suspicious $462 million transferred from Citi Bank to Stanbic Bank Zambia

On 24 September, the Lusaka Times reported on the biggest transaction recorded in Zambia under the suspicious files.

FinCEN Files investigations from across Asia

https://www.icij.org/investigations/fincen-files/fincen-files-investigations-from-across-asia/

FinCEN Files: the documents

https://www.buzzfeednews.com/article/johntemplon/fincen-files-the-documents

Blame politicians, not banks, for the FinCEN mess

An article from Coda sets out to make an make an unfashionable observation – the leaks are evidence the banks were doing what we ask of them.  Fury should not be directed at them, but at the idiocy of the system they are operating within and ultimately, therefore, the blame lies with the politicians.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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