Thread by @JulieZebrak

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.

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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