 | National Drug Intelligence Center National Drug Threat Assessment 2005 February 2005 Money Laundering
IntroductionInteragency estimates indicate that the cost to society from drug trafficking and abuse in the United States is between $60 billion and $108 billion. In 2000, the most recent year for which these data are available, ONDCP estimated annual retail-level cocaine purchases at $36 billion, marijuana at $11 billion, heroin at $10 billion, methamphetamine at $5.4 billion, and other substances at $2.4 billion (see Figure 66). These figures do not include the estimated dollar figure for drugs purchased at wholesale or midlevel, meaning that the amount of drug-related currency generated in the United States may be significantly greater than the $60 to $108 billion estimated.
Primary Market Areas are principal areas in which illicit drug proceeds are generated.21 These are areas where significant levels of wholesale- and retail-level drug distribution occur (see map,Figure 1 in Scope and Methodology section). According to ICE, as much as $4 billion to $8 billion are generated from illicit drug sales in the New York metropolitan area each year. Billions in illicit drug proceeds are generated in areas other than Primary Market Areas, particularly in areas along the Southwest Border where most drugs enter the United States and in metropolitan areas where drug abuser populations are large. Colombian and Mexican DTOs are the most prominent wholesale-level drug distributors in the United States. Their drug distribution activities span numerous cities and states throughout the country, generating billions of dollars in illicit drug proceeds annually. Those proceeds usually are transferred back to Colombia and Mexico via the smuggling of bulk cash and monetary instruments (checks and money orders) as well as MSBs. Colombian and Mexican traffickers, among others, use traditional financial institutions, trade-based businesses, and informal value transfer systems (IVTS) including the Black Market Peso Exchange (BMPE) to launder illicit drug proceeds. Suspect Sentenced for Laundering Colombian Drug Proceeds On January 5, 2004, the U.S. Attorney's Office for the District of Utah announced the sentencing of a naturalized U.S. citizen from Bogotá, Colombia, to an 87-month term in federal prison for his role in a Utah-based money laundering operation. The defendant pled guilty in June 2002 to money laundering conspiracy, money laundering, and structuring financial transactions to evade reporting requirements. Prosecutors report that between January 1998 and January 2002, the defendant, his wife, and two associates laundered over $5 million in Colombian drug proceeds that were derived primarily from wholesale-level cocaine and heroin transactions in the United States. The defendant and his wife were arrested on January 13, 2002, after FBI agents obtained evidence that they were part of a conspiracy in which Colombian drug traffickers were directing them and coconspirators to travel to U.S. cities such as New York to pick up illicit drug proceeds from anonymous couriers. Once the funds were transported back to Utah, the suspect and his wife and the coconspirators used various methods to launder the cash, including purchasing cashier's checks and money orders, depositing amounts of cash under $10,000 into financial institutions, effecting wire transfers, falsifying invoices, and using the BMPE. (See Informal Value Transfer Systems for information on BMPE.) On occasion, the defendant, his wife, and the coconspirators also smuggled bulk U.S. currency to Colombia on commercial flights. Source: U.S. Attorney's Office for the District of Utah. Members of Dominican criminal groups, national-level street gangs such as Gangster Disciples and Latin Kings, OMGs, and Caucasian local independent dealers are the prominent retail-level drug distributors in the United States. Profits generated from retail drug distribution typically are laundered in the area where the drugs are sold, usually by commingling drug proceeds with legitimate proceeds through cash-intensive businesses and by purchasing high-value items such as luxury cars and jewelry. The USA PATRIOT Act has the potential to impact money laundering in the United States. Specifically, Title III of the Act was implemented to increase law enforcement's ability to prevent, detect, and prosecute international money laundering including the use of bulk cash and monetary instrument smuggling, MSBs, traditional financial accounts, and IVTS. The sections of the BSA that were amended and improved under Title III empowered law enforcement to better counter international money laundering activities that negatively impact the United States. To Top To Contents Bulk Cash and Monetary Instrument SmugglingThe physical transportation of bulk cash and monetary instruments is a principal method used by drug traffickers to move illicit drug proceeds from domestic drug markets to other U.S. and foreign destinations. Most such movement involves overland conveyances (commercial and private vehicles); however, couriers aboard commercial aircraft, buses, or trains as well as express mail services also are used. EPIC seizure data indicate that law enforcement officials who participated in Operations Convoy and Pipeline seized $221 million in U.S. currency from overland conveyances (commercial and private vehicles) from 2001 through 2003, while those who participated in Operation Jetway seized $56 million in U.S. currency at airports, train and bus terminals, package shipment facilities, U.S. post offices, and airport hotels and motels (seeTable 26).22The amount of U.S. currency seized via Operation Jetway decreased from 2001 through 2003, but U.S. currency seizures via Operations Convoy and Pipeline have remained high, possibly indicating an increased reliance by traffickers on overland bulk currency transportation using commercial and private vehicles. Available data make it impossible to determine what proportion of the seized funds were generated through drug trafficking; however, law enforcement reports that much, if not most, of the seized cash represents drug proceeds.
Prior to the USA PATRIOT Act, an individual smuggling bulk quantities of cash was charged solely with a CMIR (Report of International Transportation of Currency or Monetary Instruments) violation (failing to file appropriate documentation). The smuggling of more than $10,000 was not a criminal act. However, the enactment of Title III, Subtitle C, Section 371 of that Act made it a criminal offense to conceal and smuggle or attempt to smuggle more than $10,000 in currency or monetary instruments out of or into the United States. If convicted of bulk cash smuggling under the USA PATRIOT Act, defendants face a maximum sentence of up to 5 years' imprisonment and the forfeiture of seized cash and any property, real or personal, involved in the offense. Source: USA PATRIOT Act. Colombian and Mexican DTOs, among others, typically collect and store illicit drug proceeds at stash houses located in and near domestic drug markets before transporting the money in bulk to intended destinations. With some exceptions, the traffickers generally transport illicit drugs north from the Southwest Border and the southeastern United States (particularly south Florida) to drug markets throughout the United States and illicit drug proceeds in the reverse direction. According to EPIC Pipeline, Convoy, and Jetway seizure data from 2001 through 2003, California, Illinois, New York, and Texas were the primary origins of U.S. currency seized in these operations (see Table 27). Arizona, California, Florida, and Texas were the primary destinations (seeTable 28). From these destination points, the currency usually is smuggled to drug source countries such as Mexico and Colombia. Most of the currency seized was destined for Mexico, Colombia, and other known drug source countries such as Jamaica and those in Southeast and Southwest Asia. Illicit drug proceeds also are transported from drug markets through and between POEs along the Northern Border into Canada.
Significant U.S. Currency Seizures in 2004 On January 12, 2004, a deputy with the Bradley County (TN) Sheriff's Office seized over $1.2 million from a rented sport-utility vehicle traveling south on I-75 near Cleveland. According to officials, the deputy initially stopped the vehicle for driving erratically and tailgating. The driver told the deputy that he was traveling from New York to Mexico via Houston. The deputy requested and received consent to search the vehicle. During his search, the deputy noticed foam padding from the rear seats on the floor. Upon further inspection, the deputy found $1.1 million packed inside two suitcases that were concealed in hollowed-out compartments in the vehicle's two backseats. The deputy found additional currency in the rear doors. The driver and a passenger disavowed ownership of the currency but admitted that the money was proceeds from a recent delivery of over 100 pounds of cocaine that they had made to New York City. The driver and passenger were arrested, the vehicle was impounded, and the currency was seized. Source: Bradley County (TN) Sheriff's Office. On March 30, 2004, the Nebraska State Patrol seized $2,167,688 from a rental van at a truck stop on I-80 west of Omaha and arrested two males. Most of the currency was vacuum-sealed in 40 packages containing $5,000 to $82,000 each and concealed in two suitcases and a backpack, which were placed in the rear cargo area of the van. The backpack also contained currency--in $20, $50, and $100 denominations--that was not vacuum-sealed. One of the occupants denied knowledge of the money; however, the other individual indicated that he had obtained the currency from a man in Chicago and was transporting it to San Diego. A check of their criminal histories revealed that one of the occupants had prior drug-related arrests and the other was associated with previous currency seizures at the San Diego International Airport. Source: Nebraska State Patrol. To Top To Contents Money Services BusinessesDrug traffickers in the United States frequently use MSBs--particularly money transmittal, currency exchange (casas de cambio), and check-cashing businesses--to launder drug proceeds. MSBs filed 214,966 SARs with FinCEN from October 1, 2002, to December 31, 2003. Of those SARs, 132,439 (62%) were filed by money transmittal businesses. During the same period states with the most MSB SAR filings were New York (47,452), California (38,008), Arizona (24,946), Texas (18,431), and Florida (15,667) (see Table 29).
The term money services business (MSB) refers to five distinct types of financial services providers: currency dealers or exchangers; check cashers; issuers of traveler's checks, money orders, or stored value (prepaid debit cards); sellers or redeemers of traveler's checks, money orders, or stored value; and money transmitters. The five types of financial services are complementary and are often provided together at a common location. MSBs have grown to provide a set of financial products that customers traditionally relied on banks to provide. For example, an MSB customer who receives a paycheck can take the check to a check casher to have it converted to cash. The customer can then purchase money orders to pay bills. Finally, the customer may choose to send funds to relatives abroad, using the services of a money transmitter. All these services are available without the customer needing to establish an account relationship with a bank or credit union. These businesses perform valuable services for a wide array of individuals. MSBs have been subject to currency transaction reporting rules since the inception of the BSA in 1970;23 subsequently, additional regulatory obligations have been added. In 1988 Congress enacted Section 5324 of the BSA, requiring sellers of monetary instruments for $3,000 or more in currency to verify the identity of the purchasers. The Money Laundering Suppression Act of 1994 mandated a system of registration for MSBs. This was considered a necessary first step toward identifying a universe of financial service providers that was largely unregulated at the federal level, extremely diverse both culturally and in size, and generally unknown to federal regulators beyond the handful of large, well-known corporate entities. FinCEN proposed implementing registration regulations in 1997 with a proposal to require the filing of SARs, and FinCEN finalized the rules in 1999 with a phased-in implementation period so that all initial registrations for existing MSBs were required to be filed by December 31, 2001. MSBs also were required to begin filing SARs in January 2002. In April 2002, in response to the mandate of section 352 of the USA PATRIOT Act that financial institutions institute anti-money laundering programs, FinCEN issued a final rule requiring MSBs to establish anti-money laundering programs reasonably designed to prevent such businesses from being used to facilitate money laundering and finance terrorism. FinCEN's regulations require most, but not all, MSBs to register with the Department of the Treasury every 2 years. Certain money services businesses are exempt from that registration requirement, including U.S. Postal Service outlets; businesses that are considered MSBs solely as issuers, sellers, or redeemers of stored value; and branch offices and agents of an MSB.24 With the exception of check cashers and issuers and sellers or redeemers of stored value, all MSBs are required to report suspicious transactions. All MSBs are required to establish written, risk-based, anti-money laundering programs; to file currency transaction reports for cash transactions of more than $10,000; and to collect and maintain customer information for purchases of bank checks or drafts, cashier's checks, money orders, or traveler's checks of $3,000 to $10,000 inclusive, as well as for transmittals of funds in the amount of $3,000 or more. The civil penalty for noncompliance with the program, recordkeeping, or reporting requirements of the BSA is a fine up to $5,000 for each violation; the criminal penalty is up to 5 years' imprisonment. Source: Financial Crimes Enforcement Network. Drug traffickers frequently use money transmittal businesses to launder drug proceeds, as those businesses provide quick and easy fund transfers from one point to another. Law enforcement reporting and other available data indicate that Mexican DTOs and criminal groups often wire transfer drug proceeds from primary and other market areas to southwestern states and foreign destinations. Drug proceeds wire transferred to southwestern states frequently are physically transported into Mexico.
On February 23, 2004, the Manhattan District Attorney announced that an unlicensed Manhattan money transmittal business was convicted of conducting illegal offshore transactions worth billions of U.S. dollars--including transactions involving drug proceeds--at various locations including the Caribbean, Middle East, and South America. The corporation, which operated from April 1994 to February 2003, was convicted on four counts of operating as an unlicensed money transmitter in violation of New York banking laws. Evidence presented at trial revealed that the corporation transmitted funds from numerous sources including individuals, shell corporations, and South American exchange houses known as casas de cambio. The Manhattan District Attorney's Office showed that from 1997 through February 4, 2003, the business made more than $6 billion worth of illegal wire transfers to or from approximately 40 of the corporation's accounts. The District Attorney has initiated asset forfeiture proceedings against more than $13 million that was frozen in the corporation's bank accounts. Law enforcement officials learned of the corporation's illegal activity during a separate investigation. Source: Manhattan District Attorney's Office. Drug traffickers also use currency exchange businesses (referred to as casas de cambio in the Southwest) to launder drug proceeds. When laundering proceeds through currency exchange businesses, most traffickers use those businesses that also offer wire transfer services so that they may convert U.S. drug dollars into the desired foreign currency, then wire transfer the funds into a foreign bank account. Because currency exchange businesses are subject to MSB reporting requirements, traffickers attempt to structure transactions below reporting thresholds. Traffickers sometimes purchase check-cashing businesses and co-opt corrupt owners or employees of such businesses to launder drug proceeds. Proceeds are laundered through such businesses, typically by using funds generated through drug sales to cash checks presented by customers. The checks are then deposited into the business's bank accounts. Such transactions generally do not prompt Currency Transaction Report (CTR)25 filings as no cash is exchanged. In addition, when considering the normal business function of check-cashing businesses, the transactions appear legitimate. From a check-cashing business, traffickers also can send third party checks to destinations in and out of the United States, where the checks are cashed. To Top To Contents Traditional Financial InstitutionsTraffickers launder drug profits through traditional depository institutions--banks, thrifts, savings associations, and credit unions--typically through structured transactions, particularly deposits; however, traffickers also structure other transactions. Depository institutions also are used to purchase bank drafts and cashier's checks that can be transferred to any location inside or outside the United States. Most structured deposits involve less than $5,000 in currency to avoid the possibility of a SAR being filed. Traffickers also use traditional financial institutions to wire transfer funds from account to account to make it more difficult for law enforcement personnel to track the funds; however, because of increased regulations regarding such wire transfers, traffickers are using intrabank transfers, which are not as strictly regulated. Verification of Identification The USA PATRIOT Act, Title III, Section 326, increased scrutiny of financial accounts by requiring certain financial institutions to implement and customers to comply with the following three provisions:
Source: USA PATRIOT Act. From 2001 through 2003 depository institutions filed 765,704 SARs, 288,243 of which were filed in 2003 alone.26 Of the number filed in 2003, 155,468 indicated a BSA/Structuring/Money Laundering violation--the only specific money laundering violation.27 According to FinCEN, California, New York, Texas, Florida, and New Jersey were the states with the highest number of BSA/Structuring/Money Laundering violations during that period (see Table 30).
Bank Accounts Used to Launder Illicit Drug Profits On January 13, 2004, the U.S. Attorney's Office for the District of New Jersey announced the indictment and arrest of five members of a drug trafficking/money laundering organization who conspired with two Ecuadorian nationals to launder illicit drug profits by structuring currency transactions at banks in New Jersey and New York. From January 1998 through November 2000, five defendants allegedly conspired with the two Ecuadorians to deposit over $11 million into 54 bank accounts at several banks for various corporate entities, including the accounts of a supermarket franchise. Most of the cash deposits were less than the $10,000 CTR reporting requirement. The bank deposits and money transfers were eventually transmitted to Ecuador and Colombia. Source: U.S. Attorney's Office for the District of New Jersey. To Top To Contents Front and Shell CompaniesDrug traffickers often use front companies to launder illicit drug proceeds. Front companies appear as legitimate business enterprises. Most are trade-based, cash-intensive businesses such as auto repair stores, beauty salons, nail boutiques, bodegas (small grocery stores), liquor stores, bars, restaurants, and construction companies as well as charities through which drug proceeds may be commingled and deposited with legitimate proceeds generated at the businesses. Various criminal groups and independent dealers use front companies to launder drug proceeds. The practice is very common among Dominican and Mexican criminal groups, national-level street gangs such as Gangster Disciples and Latin Kings, and OMGs. Record Business Used as Front Company On February 17, 2004, the U.S. Attorney's Office for the Northern Division of the District of Maryland announced the conviction of four individuals on charges of conspiracy to distribute crack cocaine and money laundering. From September 2002 to July 2003, the defendants operated a crack distribution network throughout the Baltimore metropolitan area and used the profits to finance and maintain a record production and sales company through which they laundered drug proceeds. Specifically, the group commingled crack cocaine proceeds with proceeds generated at the business when making bank deposits. Source: U.S. Attorney's Office for the Northern Division of the District of Maryland. Drug traffickers also use shell companies to launder illicit drug proceeds. Shell companies are fictitious businesses that serve no legitimate business purpose despite being registered as service providers or manufacturers. Shell companies may or may not maintain actual business locations. Most are located in countries with lax money laundering laws or high levels of corruption and conduct business through offshore banks. Traffickers use the guise of shell companies to deposit cash and to wire transfer funds between accounts. Funds Electronically Transferred Through Shell Companies According to the New York/New Jersey HIDTA, the initial recipients of large wire transfers of illicit drug profits from the New York metropolitan area are shell companies. Identifying shell corporations via wire transfer records is extremely difficult considering that U.S. banking regulators estimate that over $1 trillion is electronically transferred through the New York metropolitan area daily. Source: New York/New Jersey High Intensity Drug Trafficking Area. Informal Value Transfer Systems Drug traffickers use various IVTS, including the BMPE, hawala,hundi, and hui khan to launder and transfer illicit drug proceeds. These systems are similar in that each provides a means to transfer value from one location to another without the details of each transaction being recorded at a traditional financial institution, such as a bank or a registered money transmittal service. The BMPE is used primarily by South American, particularly Colombian, traffickers, while the hawala, hundi, and hui khan are used primarily by Southwest and Southeast Asian traffickers. The following paragraphs describe these systems in more detail. (Also see FinCEN Advisory 33, "Informal Value Transfer Systems," March 2003.) According to DEA, South American drug traffickers launder between $3 billion and $6 billion a year through the BMPE. There are many varied elements within the system; however, currency brokers are critical to its operation. Black market currency brokers serve as intermediaries between traffickers who need their home countries' currencies to pay expenses and finance drug operations and foreign consumers (primarily South American merchants) who desire U.S. currency to conduct international business transactions. Brokers typically accept bulk cash from traffickers and charge a percentage fee on each end of the transaction--that is, the seller (trafficker) and the purchaser (merchant) of the funds. Brokers also attempt to profit from differences in exchange rates. South American merchants, particularly those in Colombia, often resort to the BMPE to obtain dollars since it is generally more efficient and less costly than purchasing currency through the official banking system. Many merchants who use the BMPE attempt to smuggle or falsely invoice goods purchased into their home countries to avoid taxes and tariffs or because they have no documentation that the funds used to purchase the commodities came from a foreign country. (For more information, please see FinCEN Advisory 9, "Colombian Black Market Peso Exchange," November 1997, and Advisory 12, "Black Market Peso Exchange Update," June 1999.) Black Market Peso Exchange System Used to Launder Drug Proceeds On May 4, 2004, the U.S. Attorney's Office for the Southern District of New York announced the indictment of 34 members of a money laundering organization that operated in the United States, Canada, and Colombia using the BMPE system. The indictment charged five individuals as "first-tier peso brokers" who made contracts directly with DTOs, two as "second-tier peso brokers" who arranged the pickup of drug proceeds and placed the funds into financial accounts, and nine as "third-tier peso brokers" who made contracts directly with Colombian merchants interested in purchasing U.S. dollars at discounted prices. The indictments resulted from a 2-year OCDETF investigation dubbed Operation White Dollar. The investigation also resulted in the forfeiture of $20 million in laundered funds and the subsequent seizure of more than $1 million from 20 separate bank accounts. Source: U.S. Attorney's Office for the Southern District of New York. To Top To Contents Some drug traffickers in the United States, particularly those of Southwest or Southeast Asian descent, use hawala, hundi, or hui khan to launder and transfer drug proceeds. These IVTS have existed for thousands of years. The systems are similar to money remittance firms in that individuals can transfer funds throughout the world. However, unlike most wire remitters, these systems provide service to areas where modern financial services often are unavailable, inaccessible, or unaffordable. Hawala, hundi, and hui khan businesses can be established at any location. In the United States, most such businesses are located in communities with large Southeast and Southwest Asian populations and operate legally, provided they are appropriately licensed with the state in which they do business, appropriately registered with FinCEN, and otherwise comply with applicable state and federal laws such as the BSA. Heroin Traffickers Use Hawalas to Transfer Illicit Drug Proceeds In August 2003 the U.S. Attorney's Office for the District of Maryland announced the indictment of 11 individuals in connection with an international heroin trafficking and money laundering operation with ties to Canada, Pakistan, the United Kingdom, and the United States.Suppliers in Pakistan transported heroin via commercial aircraft from Pakistan through the United Kingdom for further transport to the United States and Canada. Funds generated through the sale of the heroin in the United States were provided to illegal hawaladars (individuals operating hawalas) operating in Maryland, Virginia, and California and transferred to recipients in Pakistan. Source: U.S. Attorney's Office for the District of Maryland. To transfer funds via these systems, the sender contacts a business or individual that offers hawala, hundi, or hui khan services (hereafter referred to as broker) and provides the broker with the amount of money to be transferred as well as information regarding the name, geographic location, and contact number of the recipient. The sending broker then gives the customer a code, such as the serial number of a bank note, which is to be passed on to the recipient for identification purposes. The sending broker keeps the funds and contacts a broker (usually a relative) in the area near the recipient by telephone, fax, or e-mail to complete the transaction. The receiving broker pays the recipient from his own funds. Each broker charges a fee on the transaction and profits from differences in exchange rates. Brokers settle debts via cash, checks, wire transfers, or deposits to joint bank accounts as well as by the trading of precious metals and gems or by providing in-kind services. Informal Value Transfer System Registration Requirements Prior to the passage of the USA PATRIOT Act of 2001, hawala, hundi, and hui khan businesses were not explicitly defined as money transmitters under the BSA. However, Section 359 of the USA PATRIOT Act amended the BSA definition of a money transmitting business to include "any person who engages as a business in an informal money transfer system or any network of people who engage as a business in facilitating the transfer of money domestically or internationally outside of the conventional financial institution system." Assuming these entities are not acting as agents of another MSB, such businesses must register with FinCEN as money services businesses; even if these businesses are not required to register, they are required to comply with the anti-money laundering program, recordkeeping, and reporting requirements of the BSA applicable to MSBs. Businesses that are required to be licensed by a state or that are required to register as MSBs with FinCEN but fail to do either may be in violation of the BSA and may be criminally liable pursuant to 18 USC 1960. Violators may face both criminal and civil penalties. Source: USA PATRIOT Act. Other Money Laundering TechniquesDrug traffickers use various other techniques to launder illicit proceeds that involve money orders, debit cards, automated teller machines, the precious gems and metals trade, and casinos, as well as schemes involving real estate, attorneys, and the insurance industry. Traffickers' use of these and other businesses is limited only by their imaginations. Insurance Products Used to Launder Drug Proceeds On December 6, 2002, a 2-year federal investigation dubbed Operation Capstone revealed that Colombian drug traffickers were purchasing and quickly liquidating investment-grade insurance policies to generate income that appeared to be the proceeds of legitimate insurance products. Investigators estimate that $80 million in drug proceeds was laundered via this technique. Since December 2003 Operation Capstone resulted in numerous enforcement actions including the seizure of approximately $9.5 million by ICE officials in Miami, Florida; the indictment of five Colombian nationals in Miami for laundering approximately $2 million in drug proceeds through insurance companies; the seizure of approximately $20 million in insurance policies, bonds, and cash; and the arrest of nine individuals in Colombia by Colombian officials. Source: U.S. Department of State. To Top To Contents OutlookTraffickers will continue to rely on the physical transportation of bulk cash (primarily overland in commercial and private vehicles), wire transmittal businesses, and IVTS such as the BMPE system to facilitate laundering their illicit funds, as these techniques have proven effective for some time. Colombian and Mexican traffickers will remain the primary launderers of proceeds generated through wholesale-level drug transactions, while members of Dominican criminal groups, national-level street gangs such as Gangster Disciples and Latin Kings, OMGs, and Caucasian local independent dealers will remain the primary launderers of proceeds generated through retail-level transactions. Arizona, California, Florida, Illinois, New York, and Texas will remain the most problematic money laundering areas in the United States, as those states contain primary drug market areas in which significant amounts of drug proceeds are generated. Much progress has been made in strengthening anti-money laundering regulations and penalties, particularly since the enactment of the USA PATRIOT Act. To significantly disrupt traffickers' ability to launder and use illicit drug proceeds will require extensive cooperation among regulatory and law enforcement agencies and the collection and analysis of money laundering intelligence at every level of the drug trade. Training and standardized reporting are critical to this effort. End Notes20. Some of the SARs relate to those filed by affiliates of depository institutions or, in some cases, filed voluntarily by MSBs prior to January 2002, by brokers and dealers in securities who were not affiliated with banks, or by gaming businesses that, during the time period, were not required under the BSA to file SARs. | |||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||||
End of page.
