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Wow. @BuzzFeedNews has achieved the impossible. They’ve made financial intelligence sensational and sexy. 
Anyway, here’s a thread on my observations: https://twitter.com/buzzfeednews/status/1307726786596347906
Anyway, here’s a thread on my observations: https://twitter.com/buzzfeednews/status/1307726786596347906
1) First of all, let’s talk sourcing. Where did the information come from, and how? (Yes, I have a thing about this.) It was leaked by a FinCEN employee back in 2017-2018. So yes, I believe these are real SARs and we know the provenance of the info. https://abcnews.go.com/US/treasury-official-pleads-guilty-unlawful-disclosures-leaking-info/story?id=68256328
(For anyone not familiar: FinCEN is the US’s Financial Intelligence Unit, and a SAR is a suspicious activity report. In Canada, this is a suspicious transaction report)
2) You may initially react to Buzzfeed’s characterization of Western banks allowing money laundering to flourish and people to profit from criminal activity. It’s a bit sensational and could be nuanced, but yeah. It’s a thing.
3) The article definitely gets this wrong: “the SAR program became more about mass surveillance than identifying discrete transactions to disrupt money launderers”. The SAR program is actually a targeted program.
4) Of course, what amounts to “suspicion” (and thus forms the grounds for filing a report) is highly subjective, and the program has been used defensively by banks to create plausible deniability.
5) If you actually want mass surveillance in the financial sector, you have to look to mandatory reporting requirements - how about EVERY transaction of 10k or more (as in many jurisdictions), or EVERY international funds transfer (as in Australia). Now THAT’S mass surveillance.
7) This is LITERALLY unbelievable: “A source familiar with the matter told BuzzFeed News that FinCEN’s database did not contain SARs on either Trump or the Trump Organization”
8) Like, seriously? Given all the financial irregularities associated with this presidency, and there isn’t a SINGLE report? Or even about his being a politically-exposed person? I find this extremely implausible.
9) Here’s the BBC on this: The FinCEN files are ~2500 documents filed between 2000 and 2017. https://www.bbc.com/news/uk-54226107
10) I haven’t seen any Canadian reporting on this story, but looking at ICIJ’s website, there are at least 183 transactions in the dataset, totalling around ~16million (both incoming and outgoing). Any Canadian reporter looking at this, hit me up for analysis & comment.
11) While I agree that this is largely bad news, Buzzfeed didn’t mention the possibility that some of these accounts might have been subject to a “keep open” order or request - that is when banks are asked to keep an account open and active in order to observe transactions.
12) This is relatively common in investigations, but banks are still likely to file SARs during this time. (KYA)
And some more detailed reporting: “North Korea carried out an elaborate money laundering scheme for years using a string of shell companies and help from Chinese firms, moving money through prominent banks in New York” https://www.nbcnews.com/news/world/secret-documents-show-how-north-korea-launders-money-through-u-n1240329
