USE OF BSA REPORTING BY THE FBI

BSA Requirements

• The regulators• Your customer• Money Laundering – traditional targets

The FBI Mission

• Criminal Investigations• National Security Investigations• Terrorism Investigations

Terrorism Investigations

• Terrorism Finance• Utilization of information in CT cases• Nuances of a CT investigation• Additional elements of proof• Early investigations -use of FINCEN reporting

Terrorism Finance Landscape

• Illegal activities to Support terrorism operations.

• Illegal activities to fund terrorism operations • Legitimate funds contributed by supporters• Legitimate funds contributed by unwitting

donors.• NGOs

9/11

• The events of 9/11 and the drive to promote information sharing

• Creation of other Federal Agencies• The Patriot Act• Impact from FISA to Financial Institutions

BSA Reporting

• Reporting cycle• Integration of information• The volume of information• Exploiting the data• Coordination with other Agencies

Integration with other Agencies

• SAR Task Forces• Financial Intelligence groups• Fusion Centers• Placement of personnel at other agencies.

314(b) Voluntary Information Sharing

• Promote and protect communication between financial institutions

• Safe Harbor for institutions to exchange information concerning individuals, entities, organizations or countries suspected of possible terrorist or money laundering activities

• 3,900 Institutions (as opposed to compulsory314(a) programs 19,000 members)

Egmont Requests

• Network of International Financial Intelligence Units (FIUs) – 131 member FIUs (FinCEN=U.S. FIU)– Responses considered informal for lead value only.

Supervisory Special Agent John J. LiguoriNew York Office

26 Federal Plaza, 28th FloorNew York, NY 10278

212-384-3914