TLDR – Reactions are mixed to BuzzFeed News and the International Consortium of Investigative Journalists’ (ICIJ) reporting around the unauthorized leaks of a trove of unclassified but law enforcement sensitive Suspicious Activity Reports (SAR) filed by some of the largest and well-known global financial services firms. Regardless of opinions specific to the release of the information and surrounding reporting, more can always be done to improve AML regimes.
The end of the third quarter – as well as the start of the fourth – of 2020 has proven to be full of news, from the BuzzFeed News and ICIJ FinCEN Files collaboration and the joint OFAC and FinCEN Advisories on ransomware payments to the recent release of the Cryptocurrency Enforcement Framework by the US Department of Justice.
While I’m still unpacking and reading both what BuzzFeed News and the ICIJ continues to publish, there is a tremendous wealth of commentary being generated discussing major topics, regional approaches as well as conversations on the merits of the reporting approach.
Regardless of the progress that has been made in AML regimes over the last few decades, intergovernmental progress through organizations like the Financial Action Task Force (FATF) and regional agreements can always be improved upon.
For those looking to make sense of the volume of information and ongoing discussion, I’ve assembled a handful of links to articles that will get one started.
For those of us on LinkedIn, Tim Lloyd pointed to a great article written by former US Customs Special Agent Robert Mazur, who consulted on ICIJ’s reporting. Some of you may recall Mazur as the author of the book that was the inspiration for the 2016 movie starring Bryan Cranston, The Infiltrator.
His article is a great start.
FinCEN Files Confirm the Elephant in the Room
For US practitioners, ICIJ offers a handy summary of their reporting:
A roundup of FinCEN Files reporting from North America
For our Latin American colleagues, ICIJ has a similar read:
A roundup of FinCEN Files reporting from Latin America
Not surprisingly, their reporting overlaps a number of scandals that have plagued the region over the years to include connections to international sports and Operação Lava Jato, Brazil’s Operation Car Wash on the Odebrecht construction company’s widespread bribery for public works contracts.
Finally, here’s a link to FinCEN Files-related reporting from around the globe in each listed country’s native language. I’ve been using the link to Brazil to brush up on my AML related vocabulary.
FinCEN Files stories from around the globe