Suspicious mind case study: How to mightily mitigate out of a SAR
I once worked a case that involved a Lebanese-owned, U.S.-based restaurant that alerted due to cash deposits to a business account, immediately followed by transfers to a personal account, then followed shortly by cash withdrawals from ATMs in Beirut, the capital of Lebanon.
So you might be wondering: why did Lebanon give me pause. The answer: because it has so many ties to high-profile money laundering cases and terror groups.
“Terrorist groups operating in Lebanon included Hizballah, ISIS, Hamas, and the Abdullah Azzam Brigades,” according to the U.S. government’s “Country Reports on Terrorism 2019: Lebanon.”
To read the full report, click here.
“Of these, the Lebanon-based and Iran-backed terrorist group Hizballah remained the most capable,” according to the report, adding that Israel in 2019 noted the group was producing precision-guided missiles in the country.
As well, despite the Lebanese government’s “official policy of disassociation from regional conflicts, Hizballah continued its military role in Iraq, Syria, and Yemen, in collaboration with the Iranian regime.”
Further ramping up risk: “In addition, several individuals on the FBI’s most wanted list or listed by the State or Treasury Departments as Specially Designated Global Terrorists reportedly remained in Lebanon.”
So, not surprisingly, cognizant of the regional roiling cauldron of risk, this was the distrust portion of my investigation.
The cash withdrawals alone may have been enough to have filed a SAR and be done with it.
However, the obvious nature of the cash transactions seemed as though the account holder was not trying to conceal anything from the bank or law enforcement.
I decided to look deeper to better corroborate what I was seeing.
One thing that jumped out to me: the amount of cash being withdrawn was minimal and only the location of the withdrawals was what triggered the alert.
Without contacting the customer, I dug deeper into open-source intelligence (OSINT) by Googling the account holder’s name.
While researching, I found out a key detail that helped mitigate, or somewhat douse, my original incendiary inclinations: I found a Facebook account for the customer with pictures of him and his family standing in front of the restaurant.
Here I was able to see that the restaurant did exist.
I then looked at the pictures of his family and saw that his teenage daughters had their own Facebook and Instagram accounts, both of which were public/open accounts.
After perusing the daughters’ pages, I discovered pictures of them on what appeared to be the American University campus in Beirut and other places in and around Beirut.
From these posts I was able to deduce that the daughters appeared to be utilizing the cash deposited into the personal account, thus making these transactions normal for the customer.
While this customer did not state (he probably should have alerted the bank that these withdrawals would be a normal occurrence) that he was putting money into the joint account he had with his daughters and that the cash withdrawals would be taking place from Beirut, I was able to corroborate his stated nationality and thus the account activity looked normal for him.
While every investigation is different, this is just one example of how my suspicious mind turned out to not detect any illicit activity and corroborated what made sense for the account.
These thought processes, magnified across an industry, can help better manage investigative resources and be seen as crafting effective AML programs producing intelligence that would be of use to law enforcement – the new incoming standard of the just-passed Anti-Money Laundering Act (AMLA).
So, in a sense, working to hone your “suspicion” sixth sense isn’t just a tactic to make your fincrime compliance program more ready, relevant and in-tune with regulatory expectations, it is a tacit requirement to better acclimate, adapt and adopt to a regime where the focus has shifted from easily auditable processes to investigative results.
What makes you a better investigator? Where is your mind when you open your spreadsheet and does this influence your case results?
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