Referenced in our Newsletter Volume 2, Issue 2 - February 2003

Transactional Activities Link Chart

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.