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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

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Presentation Transcript

Bsa requirements
BSA Requirements

  • The regulators

  • Your customer

  • Money Laundering – traditional targets


The fbi mission
The FBI Mission

  • Criminal Investigations

  • National Security Investigations

  • Terrorism 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
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
BSA Reporting

  • Reporting cycle

  • Integration of information

  • The volume of information

  • Exploiting the data

  • Coordination with other Agencies


Integration 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
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
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 10278212-384-3914


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