The 11 most important things in the leaked FinCEN files, which exposed $2 trillion in suspicious transactions and are roiling the world of finance (2024)

Thousands of leaked documents shared with journalists have shown how some of the world's biggest banks for years facilitated the movement of dirty money.

FinCEN is in charge of compiling "suspicious-activity reports" sent to it by banks that suspect financial wrongdoing by their clients. SARs do not constitute evidence of wrongdoing but are a way to alert regulators and law enforcement.

The documents are shared with law-enforcement and financial-intelligence groups around the world. The agency does not require banks to stop dealing with clients who prompted SARs.

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BuzzFeed News and ICIJ said the documents showed that banks including JPMorgan Chase, HSBC, and Deutsche Bank engaged with and facilitated the movement of criminal money even after raising suspicions.

The files detailed movements and transactions over almost two decades, from 1999 into 2017.

Many of the banks named in the report have responded in statements to BuzzFeed News.

Here are some of the biggest revelations to come out of the bombshell report:

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5 banks processed more suspicious money than anyone else in the leak

The names of five big banks came up more than any others in the documents.

Of the $2 trillion in suspicious transactions, $1.2 trillion moved through Deutsche Bank.

Nearly all the rest was processed by JPMorgan, Standard Chartered, Bank of New York Mellon, and Barclays.

Several other banks, including Société Générale, HSBC, State Street Corporation, Commerzbank AG, and China Investment Corporation, also processed billions.

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European bank shares — already under pressure from a resurgence of the coronavirus — have tumbled since the report was published.

Barclays shares were last down 5.4% on London's FTSE 100 index, at their lowest since late April, while Deutsche Bank shares were down nearly 9% in Frankfurt, at their weakest since late May.

The leaked documents represented 0.02% of total SARs

Reporters saw more than 2,100 leaked SARs — but this is just the tip of the iceberg.

According to the ICIJ, more than 12 million SARs were filed with FinCEN from 2011 to 2017, meaning those in the leak represented just about 0.02% of the total.

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HSBC moved money for the WCM777 Ponzi scheme that victimized thousands

The files revealed that HSBC allowed fraudsters involved with WCM777, an $80 million Ponzi scheme, to move money around the world, the BBC reported.

In 2013 and 2014, the bank moved fraudsters' money from the US to Hong Kong, despite having promised to clamp down on money laundering, the outlet reported.

In 2012, after a US Senate investigation, the bank was fined a record $1.9 billion for its role in channeling cash for what the investigators called "drug kingpins and rogue nations," the BBC reported at the time.

But the following year, fraudsters working with WCM777 were able to move more than $15 million through HSBC, despite warnings that it was a scam, the leaked documents show.

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At the time of the notice, WCM777 was barred from conducting business in three states.

The Ponzi scheme targeted poor communities in various nations and victimized thousands of Asian and Latino immigrants, according to the BBC and BuzzFeed News.

HSBC told the BBC it has always followed its legal duty in reporting such activities.

Read the full report from the BBC here.

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Banks processed millions for the family of a Kazakh politician wanted by Interpol

The documents showed that JPMorgan Chase, along with Bank of America, Citibank, American Express, and others processed millions in transactions linked to a Kazakh politician wanted by Interpol, BuzzFeed News reported.

The family of Viktor Khrapunov, a former mayor of Almaty, Kazakhstan, used JPMorgan Chase to handle millions of dollars in transactions, even after Interpol issued a so-called red notice, the outlet said.

At the time of the transactions, Khrapunov and his wife stood accused of money laundering, fraud, and the creation of an organized crime group, according to Newsweek.

They were convicted in absentia, having fled to Switzerland. They described the charges as politically motivated, BuzzFeed News reported.

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Arkady Rotenberg, a Putin associate, may have used Barclays to launder money and evade sanctions

The documents suggested that a close associate of Russian President Vladimir Putin's may have used the UK-based Barclays Bank to avoid sanctions and launder money, the BBC reported.

Arkady Rotenberg, a childhood friend of Putin's, is among several associates who were put under European Union and US sanctions following Russia's annexation of Crimea in 2014, the BBC reported. The sanctions were meant to restrict Rotenberg from conducting business with Western banks.

But companies controlled by Rotenberg appeared in numerous SARs in the leak, according to the BBC.

From 2012 to 2016, a company named Advantage Alliance moved about $77 million through HSBC. The US Senate has said there is strong evidence that the company is owned by Rotenberg. A Senate investigation found that the company was making secretive art purchases using its Barclays account to evade the sanctions, the BBC reported.

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Barclays closed Advantage Alliance's account in 2016, but leaked SARs showed that the bank continued to deal with numerous other companies thought to be owned by Rotenberg until 2017, the BBC reported.

Barclays denied any wrongdoing.

Read the full report from the BBC here.

$142 million of suspected Iranian money was processed via the UAE

US prosecutors have alleged that Gunes General Trading, based in Dubai, was used to funnel Iranian state money via the United Arab Emirates and evade international sanctions, according to the BBC.

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In 2011 and 2012, the documents showed, the UAE's central banking system processed $142 million in transactions for the company, despite them being labeled as suspicious, the BBC said.

A New York branch of Standard Chartered Bank noted hundreds of suspicious transactions from the company and flagged them to the UAE's central bank but did not mention an Iran connection, the BBC reported.

While the UAE's central bank said it alerted law enforcement and closed the accounts, Gunes General Trading used other state-owned banks to funnel another $108 million in transactions until September 2012, the BBC reported.

In 2016, the US said the company was involved in a major sanctions-evasion scheme. It has wound up within the past two years, the BBC reported.

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The Central Bank of the UAE did not respond to the BBC's request for comment.

Read the full report here.

A major donor to the UK's ruling Conservative Party was linked to the Kremlin

The husband of a major donor to UK Prime Minister Boris Johnson's Conservative Party has received money from a Putin-linked millionaire who is under US sanctions, the leaked documents showed.

The files showed that Vladimir Chernukhin, the husband of Lubov Chernukhin — who has given almost $2.2 million to the Conservative Party — was given $7.8 million by an offshore company that could be traced back to a Russian politician and oligarch named Suleyman Kerimov.

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Kerimov was one of several oligarchs named in a 2018 report by the US Treasury Department discussing "malign" Russian activity. The Treasury report said he was accused of laundering money and leaving taxes unpaid in Europe.

Lubov Chernukhin has spent time in the company of three prime ministers — and she once paid $205,000 to play tennis with Johnson, according to the BBC.

North Korea laundered money using a string of shell companies and US banks

The leaked documents suggested that despite international sanctions blocking North Korea's access to the global financial system, it has laundered more than $174.8 million, NBC News reported.

The documents show that transactions flagged as suspicious from about 2008 to 2017 were cleared through US banks including JPMorgan Chase and Bank of New York Mellon, NBC News said.

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North Korean wire transfers flagged in the SARs were often facilitated by Chinese and shell companies, NBC News reported.

Experts told NBC News that the transactions showed all the hallmarks of money laundering.

Read the full report here.

Banks flagged Paul Manafort's activity as suspicious years before he was arrested

Bank transactions linked to Paul Manafort, President Donald Trump's former strategist who was convicted of fraud in 2018, were flagged as suspicious six years earlier, in 2012, the ICIJ reported.

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More than $50 million in payments to Manafort processed by JPMorgan Chase over 10 years attracted SARs, according to the ICIJ.

The report said the bank processed $6.9 million in transactions after Manafort resigned from Trump's campaign.

Manafort is serving a seven-year sentence for tax fraud, bank fraud, and failure to report foreign bank accounts.

Deutsche Bank managers knew more than they claimed about an infamous trading scandal

2017's mirror-trading scandal — a $10 billion money-laundering scheme involving crime bosses, drug cartels, and terrorist networks — saw Deutsche Bank pay a fine and blame middle managers in its Moscow offices.

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But the leaked SARs showed that awareness of the issues at the heart of the scandal went far higher in the company, BuzzFeed News reported.

According to BuzzFeed News, warnings of serious failings at the company were sent to the bank's chair and its supervisory board.

Bank of America was so concerned that it submitted a SAR about Deutsche Bank's dealings — and then its managers were asked to leave Deutsche Bank's building when they attempted to discuss the matter in London, BuzzFeed News reported.

Christian Sewing, now Deutsche Bank's CEO, ran the audit office overseeing the bank's Moscow dealings, but he gave the office the all-clear, BuzzFeed News reported.

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Deutsche Bank told BuzzFeed News that Sewing was not personally involved in the Moscow audit.

Read the full story here.

Financial regulators catch only a small fraction of the activity behind dirty money

The FinCEN leak includes 2,100 SARs, but they're a fraction of what's out there.

Banks often don't know or don't follow up on their inquiries about the ultimate owners of the accounts they process, the ICIJ reported.

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David Lewis, executive secretary of an anti-money-laundering group called the Financial Action Task Force, told the ICIJ that compliance was more often about going through the motions than taking real action.

"Everybody is doing badly," Lewis said.

A 2011 report by the United Nations Office on Drugs and Crime estimated that less than 1% of global illicit financial flows were seized and frozen.

Read the full story here.

The 11 most important things in the leaked FinCEN files, which exposed $2 trillion in suspicious transactions and are roiling the world of finance (2024)

FAQs

What are the FinCEN Files all you need to know about the documents leak? ›

The FinCEN Files refer to a collection of more than 2,100 suspicious activity reports (SARs) leaked from the United States Financial Crimes Enforcement Network (FinCEN). The SARs were filed by banks and other financial institutions between 1999 and 2017, and they involve transactions totaling over $2 trillion.

What is the FinCEN Files scandal? ›

The FinCEN Files implicate former Mexican president Enrique Peña Nieto in money laundering. The files revealed that Group Grand Limited was controlled by Alex Saab and Álvaro Pulido. NBC News reported that North Korea laundered money through US banks via shell companies and Chinese firms.

What are three pieces of customer information that may be considered suspicious? ›

transactions that don't match the customer profile. high volumes of transactions being made in a short period of time. depositing large amounts of cash into company accounts. depositing multiple cheques into one bank account.

Which of the following transactions are suspicious from money laundering perspective? ›

Transactions that cannot be matched with the investment and income levels of the customer. Requests by customers for investment management services (either foreign currency or securities) where the source of the funds is unclear or not consistent with the customer's apparent standing.

What are the FinCEN priorities? ›

In no particular order, these include: corruption, cybercrime, domestic and international terrorist financing, fraud, transnational criminal organizations, drug trafficking organizations, human trafficking and human smuggling, and proliferation financing.

What are FinCEN money laundering priorities? ›

The release identifies eight priorities, covering money laundering related to: (i) corruption and kleptocracy; (ii) cybercrime, including as it relates to cybersecurity and virtual currency; (iii) international and domestic terrorist financing; (iv) fraud; (v) transnational organized crime; (vi) drug trafficking; (vii) ...

What are the five key components of an effective suspicious activity report? ›

An effective SAR has five vital components2:
  • Introduction. The introduction to a SAR should begin with the reason for the filing, including the type of activity being reported. ...
  • Account Information. ...
  • Due Diligence/Investigation. ...
  • Dates and Activity. ...
  • Closing Statement and Conclusion.
Oct 14, 2022

What would be considered suspicious activity? ›

Suspicious activity can refer to any incident, event, individual or activity that seems unusual or out of place. Some common examples of suspicious activities include: A stranger loitering in your neighborhood or a vehicle cruising the streets repeatedly. Someone peering into cars or windows.

What are red flags in AML? ›

In Anti-Money Laundering (AML) compliance, a red flag describes a warning sign that indicates the possibility of money laundering or other criminal activity. Red flags can include transactions involving companies in sanctioned jurisdictions, large volumes, or funds being transmitted from unknown or opaque sources.

What are the red flags in transaction monitoring? ›

Frequent cross-border flow of transactions, especially with high-risk countries. A large amount of cash deposited in smaller portions. A large amount of cash deposited in an account at once. Payment received in account, not matched with goods shipped or trade-based money laundering.

What are the red flags for money laundering transactions? ›

Common red flags include large cash transactions, structuring transactions to avoid reporting thresholds, rapid movement of funds, unusual customer activity, lack of business justification, dealing with non-resident customers or Politically Exposed Persons, offshore transactions, unregistered or unlicensed entities, ...

What are the FinCEN Files for JP Morgan? ›

The FinCEN Files show that five global banks — JPMorgan Chase, HSBC, Standard Chartered Bank, Deutsche Bank and Bank of New York Mellon — moved illicit cash for shadowy characters and criminal networks even after U.S. authorities fined these financial institutions for earlier failures to stem flows of dirty money.

What are supporting documents for FinCEN SAR? ›

Supporting documentation includes relevant business records such as copies of instruments; copies of money transfer forms; receipts; sale, transaction or clearance records, and photographs, surveillance audio and/or video recording medium.

What are the different types of FinCEN reports? ›

FinCEN Currency Transaction Report (FinCEN Report 112) FinCEN Designation of Exempt Person (FinCEN Report 110) FinCEN Suspicious Activity Report (FinCEN Report 111) FinCEN Registration of Money Services Business (FinCEN Report 107)

What is the FinCEN 314 A list? ›

FinCEN's regulations under Section 314(a) enable federal, state, local, and foreign (European Union) law enforcement agencies, through FinCEN, to reach out to more than 37,000 points of contact at more than 16,000 financial institutions to locate accounts and transactions of persons that may be involved in terrorism or ...

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