The FinCEN Information By The (Very Massive) Numbers


Greater than a yr in the past, BuzzFeed Information acquired a remarkable collection of secret government documents. This large trove had been assembled on the request of legislation enforcement businesses and congressional committees investigating the 2016 presidential election and different issues. The paperwork contained personal banking details about public figures and senior authorities officers world wide — together with suspected criminals and organizations tied to terrorism.

Among the many paperwork had been greater than 2,100 suspicious exercise reviews, or SARs, which banks and different monetary establishments undergo the US Treasury Division’s Monetary Crimes Enforcement Community, or FinCEN, after they observe transactions that counsel cash laundering or different criminality. Such reviews can help investigations and intelligence gathering — however by themselves they aren’t proof of a criminal offense.

These paperwork are so intently protected that they’re by no means imagined to be accessible to the general public. You possibly can’t get them via Freedom of Data requests and you may’t subpoena them in authorized proceedings. Banks will not be imagined to admit the existence of a SAR — even to different banks. Previous to this reporting, only a few SARs are identified ever to have been revealed. BuzzFeed Information has hundreds.

2,100+ Stories

22,000+ Pages

10,000+ Topics

170+ international locations and territories

Principally relationship from 2011 to 2017, though describing some transactions that occurred as early as 1999, the paperwork present an unprecedented glimpse into global money laundering. To investigate them and crunch the numbers, BuzzFeed Information teamed up with the International Consortium of Investigative Journalists and greater than 100 associate information organizations from 88 international locations.

What ensued was a yearlong knowledge evaluation collaboration that required hundreds of hours of guide knowledge entry, the creation of custom-built digital instruments, machine studying, and specialised validation software program.

Nevertheless it all got here right down to these suspicious exercise reviews.

The Anatomy of a SAR — and How We Dissected Them

All SARs have two elements: a set of knowledge tables and a story.

The information tables lay out the sum of money beneath suspicion and the dates of exercise, in addition to detailed details about the individuals and organizations concerned — akin to their addresses, financial institution accounts, authorities ID numbers, and extra.

These tables can go on for dozens of pages, relying on the complexity of the report. BuzzFeed Information wrote {custom} software program to extract all these particulars and put them in a single database for reporters to look and analyze.

The narrative part is a written account of the circumstances that spurred the financial institution to file the report.

Some narratives are naked bones, whereas others are in-depth accounts together with particular person transactions, further events, and what the cash was purportedly getting used for. Within the FinCEN Information, these narrative parts alone got here to greater than 8,000 pages — or about 3 million phrases.

We tried writing laptop packages to robotically extract this important info, however we shortly found that it was not doable.

So with no different selection, we did it the old school manner: We learn each final web page.

On the Origin

of Species






Warfare and Peace



Delight and Prejudice



The Energy Dealer



Infinite Jest





Approximate variety of phrases in

the FinCEN Information SAR narratives.

Supply: Blotto Design (Moby-Dick, On the Origin of Species, Delight and Prejudice, Ulysses); Undertaking Gutenberg (Middlemarch, Warfare and Peace – English translation by Louise and Aylmer Maude); Web Archive (Infinite Jest); The New York Evaluate of Books (The Energy Dealer). Phrase counts are approximate and should fluctuate by version. Photographs: BuzzFeed Information; Penguin; Amazon; Barnes & Noble; Wikimedia

BuzzFeed Information; Penguin; Amazon; Barnes & Noble; Wikimedia

Supply: Blotto Design (Moby-Dick, On the Origin of Species, Delight and Prejudice, Ulysses); Undertaking Gutenberg ( Middlemarch , Warfare and Peace — English translation by Louise and Aylmer Maude); Web Archive (Infinite Jest); the New York Evaluate of Books (The Energy Dealer). Phrase counts are approximate and should fluctuate by version.

With the assistance of ICIJ’s document-collaboration platform, BuzzFeed Information and the associate newsrooms divided the duty amongst greater than 80 reporters. For every doc, the reporters captured each set of transactions talked about. After that, ICIJ submitted every “extraction” to a number of rounds of validation. It was a large effort, nevertheless it allowed us to map out greater than 200,000 of the transactions within the SARs.

This effort gave reporters entry to a better degree of structured, searchable element than FinCEN itself gives to investigators.

Along with the written SARs, BuzzFeed Information acquired lots of of spreadsheets that banks had despatched to FinCEN. Though these information typically lack the context of the written reviews, they listing greater than 100,000 transactions.

However every financial institution has a barely totally different manner of manufacturing these information. So ICIJ undertook an effort to standardize the sphere names and handle codecs to make them extra helpful to our companions.

Extra Than $2 Trillion — Sure, With a “T”

In whole, these reviews flagged greater than $2 trillion in transactions. Right here’s the way it broke down.

The Banks: The FinCEN Information include reviews submitted by practically 90 banks and different monetary establishments. This specific assortment of paperwork shouldn’t be a consultant pattern of what banks file general. Inside this subset, by far the best variety of SARs come from Deutsche Financial institution.

Listed here are the highest 10 banks represented within the FinCEN Information, plus the full worth of suspicious transactions they flagged:

One report, filed in August 2014 by JPMorgan Chase, identifies greater than $335 billion in suspicious exercise, regarding greater than 100,000 wire transfers “despatched, acquired or processed” over the course of a decade-plus by MKS, a Switzerland-based firm that trades treasured metals.

“We can not verify your report of a purported SAR from a half decade in the past of which we’ve got no information,” a spokesperson for MKS informed BuzzFeed Information and ICIJ. “We be aware, nonetheless, that referencing $335 billion in purported wire transactions over a twelve-year interval creates a false and deceptive impression in regards to the scale and scope of our treasured metallic operations.”

MKS is “pleased with our file of sustaining an industry-leading compliance program,” the spokesperson stated, “and our lengthy historical past of sustaining uninterrupted entry to monetary markets world wide.”

In whole, 130 reviews flagged at the least $1 billion to the Treasury; these big-dollar reviews account for greater than 90% of all “suspicious exercise” in these paperwork.

When banks first encounter suspicious transactions, they’re supposed to file a report inside 30 days. However that doesn’t imply all the info is well timed: SARs typically consult with a lot older transactions, even some that occurred greater than a decade earlier than. This continuously occurs when banks obtain new details about outdated transactions or shoppers, akin to when ICIJ revealed the Panama Papers; however different occasions, the reason being unclear.

The Objects of Suspicion: The paperwork present info on greater than 10,000 individuals and organizations spanning greater than 170 international locations and territories. In addition they contact virtually each state within the US.

Greater than 250 SARs reference individuals with addresses within the US, and greater than 120 with addresses in Russia. The UK, China, Germany, the United Arab Emirates, Canada, and Ukraine had been additionally widespread areas for individuals, every showing in at the least 20 reviews.

At the least 25 of the individuals named as topics have appeared on Forbes’ listing of billionaires in 2018, 2019, or 2020, based on an evaluation by ICIJ and BuzzFeed Information.

The SARs, nonetheless, are way more prone to point out organizations than individuals. The areas of these organizations learn like a the place’s the place of wealth accumulation and administration. Greater than 400 characteristic firms with addresses within the British Virgin Islands, and greater than 300 embrace Hong Kong — two fashionable locations for stashing wealth with little scrutiny.

Greater than a fifth of the SARs within the FinCEN Information embrace a topic whose “handle” is successfully clean: no avenue quantity, metropolis, state, and even nation. In some circumstances, the clean addresses are for purchasers within the financial institution’s personal company community.

Some entities have been flagged quite a few occasions within the FinCEN Information. Mayzus Financial Services, an internet fee processing firm that served shoppers concerned in a bitcoin money laundering ring, units the file, showing as a topic of 36 SARs. Second is Kaloti Jewellery International, a Dubai-based treasured metals firm that was flagged as a topic in 34 separate SARs by eight totally different banks. Listed here are the 5 topics flagged most frequently:

Responding to a request for remark, a consultant for Mayzus Monetary Providers stated the corporate takes compliance significantly and “helped to arrest on-line and offline fraudsters, corrupt remittance brokers, cash launderers, and apprehend lots of of thousands and thousands of {dollars} value of illicitly gained belongings” and that “from my perspective MFS has achieved precisely what it was imagined to be doing.”

A lawyer for Kaloti stated that the variety of SARs was “statistically insignificant” within the context of its {industry}. “Kaloti vehemently denies any allegations of misconduct, whether or not these allegations stem from as we speak or a decade in the past,” the corporate informed ICIJ and BuzzFeed Information.

Trafigura declined to remark. Veles Worldwide and Bufalo Administration didn’t reply to BuzzFeed Information’ inquiries.

What the Authorities Doesn’t Know

Final yr, banks and different monetary establishments filed greater than 2 million SARs. Authorities investigators who fight cash laundering informed BuzzFeed Information that the sheer quantity of SARs made it not possible to pay shut consideration to all of them.

“I do not suppose that we’ve got sufficient assets within the authorities to meaningfully undergo all of them,” stated Richard Elias, a former federal prosecutor for the Japanese District of California.

Though the variety of SARs filed grows yearly, FinCEN’s workers has shrunk by greater than 10% over the previous decade, based on official Treasury reports. (Along with full-time workers, FinCEN additionally employs contractors to research SARs.) In 2017, FinCEN’s appearing director testified earlier than Congress that the company confronted hiring points, partially due to how lengthy it takes to get safety clearances.

FinCEN didn’t reply to BuzzFeed Information’ requests for remark about its investigative findings. It did, nonetheless, launch a statement saying that “the unauthorized disclosure of SARs is a criminal offense,” and it introduced that it was referring the matter to the Division of Justice and the Treasury Division’s Workplace of Inspector Normal.

FinCEN makes its database of SARs accessible to more than 450 law enforcement and regulatory agencies across the nation, with greater than 13,000 customers who question the system thousands and thousands of occasions a yr.

FinCEN doesn’t require banks to file spreadsheets detailing every particular person transaction, though some accomplish that voluntarily. But it’s exactly these particulars that investigators say are most essential. “There’s nothing of better worth than having the ability to check out a sequence of wire transfers or a sequence of deposits or a sequence of withdrawals,” stated Peter Djinis, a former FinCEN analyst who helped to arrange the unique SAR system. “All of that info is so helpful.”

When banks don’t connect transaction information, analysts should comb via every report individually or request these information immediately.

The database produced by BuzzFeed Information and ICIJ gives way more readability than the person filings themselves, and has already helped our international network of reporters look at failures by governments and banks to stem the stream of soiled cash throughout the globe. ●

Emilia DíazStruck and Agustin Armendariz of ICIJ contributed reporting.