SARs Filed that Refer to Terrorism (March?September 2002)

SARs Filed that Refer to Terrorism (March ?September 2002)

FinCEN continued to examine the SAR database to determine the extent to which SARs have been filed relating to terrorism. Searches were conducted for certain keywords in the narrative portion that included: terror, terrorism, terrorist(s), September 11(th), 9/11 9/11/01, World Trade Center (WTC), Pentagon, control list, watch list, hijacking(s), and hijacker(s). Another search involved querying the violation field. The terms searched in the "Other" violation field included the words: terrorist(s) and terrorism.

Between April 1, 2002 and September 30, 2002, 717 SARs were filed that contained references to terrorism or terrorists. The following chart represents SARs filed pertaining to terrorism for the 13-month period, commencing September 1, 2001 and ending September 30, 2002.

As shown in the above chart, the number of filings began to steadily decline following a series of spikes between October 2001 and May 2002.

Listed below is more information about these SARs that reference terrorism.

Seventy-three financial institutions, including six foreign banks licensed to conduct business in the United States, filed SARs.

The suspicious activity reported in the SARs occurred in 29 states and the District of Columbia.
Violation amounts ranged from $0 to $48 million.
Financial institutions indicated that 113 (15.76%) SARs were referred directly to law enforcement. (Box 40 was checked on the SAR.)

Most of the SARs filed (531 or 74.05%) were the result of apparent matches of names on the Office of Foreign Assets Control (OFAC) and FBI watch lists, names gleaned from media reports, and as a result of subpoenas issued by law enforcement.

The activity cited in the SARs remained consistent with the activity described in Issue 4 of the SAR Activity Review (August 2002). The activity included wire transfers predominantly to and from Middle Eastern countries, the use of Automated Teller Machines (ATMs), and large cash transactions.

One hundred and fifty-three (21.33%) SARs were filed as the result of reviews of accounts with foreign indicators, unusual account activity, or unusual relationships that were not typical for a particular type of account. The focus of those SARs included:

charitable organizations and Islamic foundations;
individuals presenting personal identification from such countries as Iraq, Afghanistan and certain West Asian countries;
aviation (plane rentals and aviation schools);
wire activity to or from suspect countries (mostly the Middle East);
large cash deposits followed by wires out to suspect countries ? usually structured to avoid reporting requirements; or
large and frequent ATM activity.

Excerpted from SAR Activity Review Issue , page 21