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The Cornerstone Report: Volume 2, Issue 2

SAR Review Sparks ICE Financial Investigation in Detroit

Every day ICE special agents, intelligence specialists and contract employees review and analyze Suspicious Activity Reports (SARs). The goal—to identify criminal organizations through their behavior patterns.

Bank Secrecy Act (BSA) reporting requirements and effective anti-money laundering programs have caused criminal organizations to resort to acts of desperation in their attempt to earn, move and store their illicit funds.

Recently an analyst assigned to ICE’s Detroit Special Agent-in-Charge office was searching SARs for “red flag” indicators of criminal activity associated with countries of interest. The astute analyst identified a SAR filed by a financial institution referencing a suspicious financial transaction related to a country of interest in the Middle East.

The subject associated with the SAR was further researched and identified through law enforcement databases. The ensuing investigation entailed hundreds of investigative hours and countless grand jury subpoenas, interviews, surveillance and search warrants.

During surveillance, agents observed clandestine money drops being made in remote parking lots and the exchange of bags of currency at businesses and behind dumpsters.

Ultimately, ICE agents identified an organization operating a hawala and sending millions of dollars to foreign nations in violations of numerous U.S. laws and sanctions.

This case demonstrates the effective use of SARs by ICE to identify criminal violations that could have otherwise gone undetected and affected the integrity of the U.S. financial system and the security of the United States.

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