Referenced in our Newsletter Volume 2, Issue 2 - February 2003
Transactional Activities
The following diagram shows a sample that was derived from the Bank Secrecy Act database
containing Suspicious Activity Reports (SARs) as they were filed from their respective
financial institutions. The basic model represents transactional activities as depicted
by the SAR icons. In this case, two SUBJECTS have been identified as using the same SSN
(Social Security Number).
This data can be interpreted in two ways. The first is to consider that there was a typo
when the SSN was entered into the system and there is no "real" connection between these
individuals. Often we will see there are other common elements such as repeated
PHONES, ADDRESSES, and ACCOUNTS. Also, if the names are close in spelling or pronunciation
to each other then the pattern can be discounted.
The other interpretation is that there is collusion between these two SUBJECTS and they are
part of a larger money laundering ring. Since the ADDRESSES in this case are from different
cities (not shown in the diagram), there is suspicion that they are operating in a regional
network. Additionally, the SARs were filed by different banks, which indicates a separation
factor with respect to the filings.
It has been observed that money launderers will operate at different banks utilizing
a common SSN that is known to be "good" (e.g., won't raise any flags due to criminal
behavior as it a valid SSN and is not from a dead person). For this situation,
there were enough inconsistencies in this simple analysis to warrant a more detailed investigation.
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