WASHINGTON–A couple of trends can be seen in the Suspicious Activity Reports (SARs) filed by credit unions.
Reports filed by credit unions have made up about 10% of the more than three-million SARs filed over a recent four-year period, according to Jamal El-Hindi, deputy director, with FinCEN.
With credit unions in particular, El-Hindi said what can be seen in the reports are trends around:
- Multiple transactions below the BSA record-keeping threshold
- Suspicious exchanges of currencies
- Suspicious inquiries related to BSA reporting requirements
Where FinCEN expects to see trends in 2016, said El-Hindi, is:
- Members providing questionable or false documentation
- Suspicious scenarios around third parties
- Situations involving two or more suspicious actors working together
“The fact is that both large institutions and small institutions provide incredibly valuable information to us, and we are doing more and more to ensure our law enforcement colleagues are provided access to it and are able to do more with it,” said El-Hindi.
El-Hindi said FinCEN has become increasingly active around bogus email wire transfer fraud schemes and has identified red flags to watch for to stop email fraud.
“Since 2013, there have been approximately 22,000 cases of email compromised fraud involving $3.1 billion in transfers,” he said. “These involve impersonating victims to direct transactions. Fast communication on these issues is very important. If we can quickly identify a fraud, FinCEN can reach out to counterparts at other countries to see if it can stop further flow of transactions. Over past 18 months we have been able to help recover and return more than $200 million, simply through fast communication.”
While not particularly applicable to credit unions, he said FinCEN has grown increasingly concerned around all-cash purchases of high-end properties, especially through LLCs. FinCEN in July announced expansion of its real estate geographic targeting orders, which require identification of natural persons behind shell companies for all property financed without a mortgage. It has targeted six markets for more scrutiny: Miami/Dade/Palm Beach counties in Florida; Los Angeles County; the New York area; three counties around San Francisco; San Diego County, and counties surrounding San Antonio, Texas.