@JulieZebrak Profile picture
Jan 17, 2018 15 tweets 5 min read Twitter logo Read on Twitter
This big story by @JasonLeopold and @a_courmier_ shows how #FinCEN uses it’s suspicious activity reports/SARs collected from financial institutions (like Citibank here) to track illicit financing and connect the dots for $ laundering. You can bet Mueller has it if he wants it.
Please excuse spelling errors. A few words about SARS - #FinCEN requires banks, financial institutions, wire transfer companies, money services businesses, jewelers, etc. to file reports documenting suspicious banking activities that they witness online or in person./2
So for example, if you normally make deposits at one rate and pace, and all of a sudden your accounts starts receiving deposits once a month for $300,000 from a non-employer, your bank may file that as a SAR with FinCEN. Or if a guy walks into a bank with $19,000 in cash, and /3
Is acting all hyped up & checking over his shoulder & rushing the teller to make the deposit into an account which ordinarily doesn’t make it over $1000, his behavior + the cash (which also requires the bank to file a currency transaction report/CTR) may prompt a SAR by bank. /4
It’s not just your bank that files SARs though. As I mentioned, wire transfer companies like Western Union or jewelers who see odd sales of diamonds are also well-positioned to see suspicious financial activities and are regulated by #FinCEN & subject to the Bank Secrecy Act. /5
Oh yah - we should not forget casinos like the Trump Taj Mahal are required to file SARs for suspicious activities they witness in person or online. fincen.gov/news/news-rele…. When casinos, banks, etc. don’t have appropriate systems in place to track suspicious $ activity, /6
#FinCEN can civilly fine the money service business for failing to properly track money laundering and/or file SARS (which is what happened to Trump Taj Mahal). Why are SARS at all necessary for financial institutions, jewelers, casinos, to file? SARS provide the government w /7
With what is called Financial Intelligence (as opposed to human intelligence like spies can get). With the financial intelligence that comes in through SARS or through CTRs (mentioned above), FinCEN has an Intel Division to take all that data and analyze it to connect the dots /8
Connect the dots allows them to identify not only who (what Individual persons or companies) is doing weird $ activity but who that person is receiving the money from and who else is tied to those two people entities. And eventually to determine whether illicit financial /9
Activity can be traced to a particular source or group of sources. Such as ISIS for foreign fighters being paid to engage in terrorist activities; or Russia for ?????; or a drug cartel or gang. With the financial intel, FinCEN can generate flash reports to then send out to /10
Law enforcement to be on the lookout (BOLO!); or they may be need to alert other financial institutions about suspicious actors to watch for; or they may alert other countries/allies to beware of suspicious banking or financial activities. With respect to this Buzzfeed piece /11
It is a major violation for whomever leaked this intel to @JasonLeopold and @a_courmier_ BUT it is good scoop for sure. It shows us/reminds us that #FinCEN ALREADY is collecting info under its ordinary legal authority which may then be analyzed to link and reveal bad actors. /12
And we can all assume that the goods that #FinCEN collects and traces that relate to Manafort, Trump, Flynn, etc. will eventually be given to Mueller. Having worked @ FinCEN, my main concern is how fast can they turn the analsyes around to provide to law enforcement. The new /13
Director of FinCEN is Ken Blanco, a former colleague of mine from the Criminal Division/DOJ. His whole career has been in law enforcement as a prosecutor & helping lead the Criminal Division, including overseeing the office which goes after money laundering & kleptocracies. /14
Although I suspect Blanco is a Republican, he is a law enforcement guy through and through. In leading FinCEN, I am hopeful that Blanco will get his staff quickly turning over Financial intel to Mueller, FBI, and the Hill investigations. We are counting on you Ken! /End

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More from @JulieZebrak

Oct 9, 2018
So a few of my followers have asked me how I feel about Rod & Wray now, given their apparent complicity in the Kavanaugh “process.” I will be honest: I’ve had a pit in my stomach since Saturday. I’m much less interested in a tidbit here or there about Russia. I don’t feel like /1
Being snarky or flip. I don’t feel like looking at the news or Twitter at all. I don’t care what any pundit has to say. I’m disappointed to say the least and my wise 15-year-old reminded me tonight that Trump is temporary, and Kavanaugh isn’t going to be on the wrong side of /2
Everything all the time. She is right and offered good perspective. Watching the news and waiting for the next shoe to drop is a hard way to exist for any of us, and we’ve all been in this mode for probably the longest period of our lives. I wish I could tell you Rod has some /3
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Oct 8, 2018
I have already had 10 friends reach out about phone banking or canvassing over the next couple of weeks. I went today to canvass in VA for Jennifer Wexton who is running for the U.S. House and I was gone from 2:30-6:30. All the people I met were nice, polite, friendly. /1
It was a sunny day and I didn’t get asked any hard questions when I spoke to voters. It felt productive, it was uplifting of my spirits, and I got to spend time with a friend whom I usually don’t hang out with. Why I am I telling you? Because none of this is hard and it made /2
Me feel less powerless. Every vote counts so I know that reaching actual voters matters. I’ll be helping Abigail Spanberger next Sat in VA. During the week I will find some time to phone bank or text voters. It’s work for sure, I’d much rather do other things, but doing /3
Read 4 tweets
Oct 1, 2018
Friends: I know many of you feel as frustrated as me. Beginning October 1, it’s time to get off Twitter & get to work. There are many ways to help, but the 4 most effective ways are to knock on doors, phone bank, text voters, & donate directly to candidates. If not those, then /1
There are so many other ways to get involved. You can feed volunteers by buying snacks and drinks for campaign offices; you can open your home to host a phone bank even if you don’t want to make calls yourself; you can make lemonade stands with your kids to show support for /2
Your local candidates; you can write postcards to voters; you can volunteer to drive elderly or disabled voters on Election Day; you can do the absolute easiest job - text out the vote to remind voters of Election Day; you can buy office supplies for a local campaign office; /3
Read 8 tweets
Sep 17, 2018
A thought on drinking memories: There was a night as a freshman in college where I got myself into a prickly situation while drinking. The guy involved didn’t take advantage of me, but I was drunk. I remember it decades later b/c it was a wake up call for ME. I scared myself /1
And had a talk w myself about how I could have had a bad result. It didn’t matter that I was drunk that night or that he didn’t cross a line (thankfully). What makes me think is that the evening made a decades long impression on me. I’m sure the guy doesn’t recall at all. But /2
Here, with Ford and Kavanaugh, she too remembers. And he doesn’t recall. That isn’t surprising - maybe it didn’t happen. Maybe it did happen & he was drunk & really has no recollection. Maybe he remembers and is denying the truth. Either way, her memory is real to her. There’s /3
Read 5 tweets
Aug 14, 2018
“Sources inside FinCEN told BuzzFeed News that they were initially instructed not to hand over financial documents on certain individuals. The directive, these sources said, came from senior Treasury officials in the General Counsel’s Office.” In my /1 buzzfeednews.com/article/emmalo…
Brief tenure at FinCEN, and after 18 years at DOJ (& before that 2 yrs in private practice), I found the attorneys serving in FinCEN Office of Chief Counsel and Main Treasury’s General Counsel’s Office to be among the most risk-averse, conservative lawyers I’d ever worked with./2
This also says that FinCEN declined a committee request for an expert last year to help them analyze documents b/c “Treasury did not want to be seen as playing a part in the committee’s investigation.” Now, the request will likely be approved by Ken Blanco, the new Director. /3
Read 5 tweets
Aug 3, 2018
The rule of law requires us to reserve judgment until we have heard from all parties & completed a fair process. You cannot reach reliable factual conclusions unless you 1st weigh the credible evidence. You cannot offer reasoned legal opinions unless /2 justice.gov/opa/speech/dep…
you consider conflicting arguments.
When you follow the rule of law, it does not always yield the outcome that you would choose as a policy matter. In fact, 1 indicator that you are following the rule of law is when you respect a result although you /3 justice.gov/opa/speech/dep…
[T]he rule of law is not merely abt vesting ultimate power in judges. It is essentially abt restricting anyone from exercising arbitrary power. The goal is 2 be governed by law-by a system of clear rules & neutral processes-not by the whim of any person /4 justice.gov/opa/speech/dep…
Read 9 tweets

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