Oct 16 2009 Brett Wolf Recommended
Anti-money laundering personnel sometimes wonder if the suspicious activity reports they labor over and file are ever seen again. The answer is "yes", at least for the most part, according to Department of Justice money laundering and forfeiture guru Stef Cassella.
Cassella spoke on a panel at the recent American Bankers Association/American Bar Association AML Enforcement Conference in Washington, DC. During his frank speech, Cassella explained that "SARs most certainly are read". He added, however, that there are simply too many for law enforcement authorities to look at each and every one. He said that the department's SAR review teams tend to focus on SARs which reported apparent "Bank Secrecy Act/structuring/money laundering" offenses. This approach made sense because such SARs were relatively straightforward and investigators could generally use them to build cases.
In fact, even after authorities knew that structuring had taken place, they sometimes had trouble determining why it had occurred. Cassella said agents sometimes "spend months trying to figure out what the underlying crime was and come up with nothing". AML personnel should therefore include all available information when completing the narrative portions of SARs.
As Complinet readers may recall, Cassella spent a number of years at Main Justice, but recently agreed to help the US Attorney's Office for the District of Maryland set up its own Asset Forfeiture and Money Laundering Section. Complinet sources say that Cassella has ties to the Baltimore area. He has been sworn in as an assistant US attorney.
