The US Government Accountability Officed (GAO) issued a report finding that Suspicious Activity Report use is increasing, but the Financial Crimes Enforcement Network needs to further develop and document its form revision process.
The GAO conducted the study to assist law enforcement agencies in their efforts to combat money laundering, terrorist financing, and other financial crimes. The Bank Secrecy Act (BSA) requires financial institutions to file suspicious activity reports (SAR) to inform the federal government of transactions related to possible violations of law or regulation. Depository institutions have been concerned about the resources required to file SARs and the extent to which SARs are used. GAO was asked to examine (1) factors affecting the number of SARs filed, (2) actions agencies have taken to improve the usefulness of SARs, (3) federal agencies’ use of SARs, and (4) the effectiveness of the process used to revise SAR forms. GAO reviewed laws and agency documents; analyzed SAR filings; and interviewed representatives from the Financial Crimes Enforcement Network (FinCEN), law enforcement agencies, bank regulators, and depository institutions.
In summary, the GAO recommends that the Secretary of the Treasury direct FinCEN to further develop a strategy that fully incorporates certain GAO-identified practices to enhance and sustain collaboration among federal agencies into the forms-change process. The FinCEN Director generally agreed with the recommendation.