Synopsis of SAR Filing Activity: Credit Union Cooperatives

FinCEN researched SAR filings referencing credit union cooperatives for the period June 2004 through March 2007. The research addressed SARs filed by other financial institutions with narrative references to credit union cooperatives and terms related to terrorist financing, organized crime, fraud, scams, or money laundering. In addition, information about the cooperatives? structures and Bank Secrecy Act (BSA) compliance policies were reviewed.

FinCEN?s database queries produced 121 SARs with narrative references to credit union cooperatives and terms related to terrorist financing, organized crime, fraud, scams, or money laundering:

• Twenty-three depository institution SARs filed by credit union cooperatives;
• Four depository institution SARs and four SARs by Money Services Business (SAR-MSBs) that identified some name derivative of a credit union cooperative as a subject;
• Seventy-eight depository institution SARs and ten SAR-MSBs with narrative references to one of the cooperatives and terms related to fraud, scams, or money laundering; and
• Other instances where credit unions apparently incorrectly filed a SAR-MSB and a SAR by Securities and Futures Industries (SAR-SF) that described shared-branching transactions.

The cooperatives? SAR filings demonstrated several errors including a potential lack of consistency in the use of filer names and Federal Employer Identification Numbers (FEINs). The twenty-three depository institution SAR filings contained sixteen different filer name variations, ten different filer FEINs, and seventeen different combinations of FEINs and filer names. Analysis identified other errors in 15 of the 23 depository institution SAR filings.

Fifty of the 121 (41.32%) SAR filings with some connection to the credit union cooperatives involved fraud or attempted fraud. Seven of the 23 filings (30.43%) by cooperatives involved alleged frauds.

Excerpted from SAR Activity Review Issue 12, page 15