The FinCen Files

Criminals have been keeping their money in the bank.

Buzzfeed, the BBC and others are swooning, outraged, embittered. Money. In Banks. Who would have thought it?

This bombshell has been revealed by the leak of more than 2,500 documents, most of them Suspicious Activity Reports (SARs). The BBC gave a nudge and a wink, and revealed;

“These documents are some of the international banking system's most closely guarded secrets.”

Look, I hate to let any facts get in the way of a good narrative, but doing anything that reveals a SAR has been made, is a criminal offence. Mostly, people in the banking system, international or otherwise, try to avoid committing criminal offences. At least, before lunch.

Without seeing the source documents, and understanding the context, it’s impossible to make specific comment on the transactions highlighted. I can say that the existence of the SAR demonstrates that the bank became suspicious and filed a report to the authorities.

More will come from these files over the next week or two.

Very interesting is the light being shone on corporate structures, particularly, in the UK.

There’s a good article in the Irish Times.

LLPs are a legitimate company form. You probably know a few. Solicitors for example. However, for a long time, they have been a source of angst for compliance officers. LLPs are often owned by LLPs, which are in turn owned by offshore entities, often through multiple layers. It can be a long painstaking process to trace and monitor who owns what.

For once, the core of this problem is not the Banks. Company formation needs reform, across all jurisdictions. It wouldn’t be particularly difficult and there are plenty of experts out there to implement the project.

And yet…nobody does. Why is that, I wonder? That’s the question that I would like to see answered.