The Financial Crimes Enforcement Network (“FinCEN”) recently released a Financial Trend Analysis (“FTA”) focusing on identity-related suspicious activity. The FTA was issued pursuant to section 6206 of the Anti-Money Laundering Act of 2020, which requires FinCEN to periodically publish threat pattern and trend information derived from BSA filings.
FinCEN examined information from Bank Secrecy Act (“BSA”) filings submitted in the 2021 calendar year. According to FinCEN’s analysis, 1.6 million “BSA filings” – presumably, the vast majority of which constituted Suspicious Activity Reports (“SARs”) – were identity-related, representing a total of $212 billion in suspicious activity. These filings constituted 42% of filings for that year, thereby meaning that approximately 3.8 million SARs were filed in 2021.
The descriptions and the explanations in the FTA necessarily turn on how the SAR filings chose to describe the suspicious activity at issue. This is presumably why most of the activity falls into the vague category of “general fraud” – because, apparently, this is the particular box on the SAR form which most of the SAR filers happened to choose. However, and we will describe, the activity in fact animating the vast majority of these SARs is some form of identity theft.
Continue Reading FinCEN Analysis Reveals $212 Billion in Identity-Related Suspicious Activity