With so much focus on Suspicious Activity Reports thanks to my colleagues' #FinCENFiles coverage, it's instructive to see a real world example of how law enforcement uses SARs to investigate crimes. So, here's the story of how the feds busted money launderers using a SAR 1/

In the fall of 2011, federal prosecutors in Brooklyn were about a year into their secret investigation of corruption in global soccer. At that point, they had charged nobody, flipped nobody, and had only a few leads. Around then, an IRS agent from California joined the case. 2/

One of the first things he did was to draw up a list of potential suspects and then contact the Financial Crimes Enforcement Network, or FinCEN, the agency within the Treasury that compiles SARS. He asked for any SARS naming those people, in hopes that he'd find something. 3/

Two of the names were Daryl and Daryan Warner, the sons of Jack Warner, a former FIFA Vice President from Trinidad who was notorious for his alleged corruption. The agent struck gold. Just a few months earlier, in fact, JP Morgan Chase had filed a SAR on Daryan Warner. 4/

Warner had gone into a Chase branch in New York to deposit €7,500. When the teller informed him that based on that day's exchange rates it amounted to over $10K, he asked for €500 back. That was a red flag. 5/

Under US law, all cash transactions over $10K must be noted to the gov't on a Currency Transaction Report. To the teller, Warner taking back €500 looked like he was intentionally trying to avoid triggering a CTR, which can be used to monitor money laundering activity. 6/

So, without saying a word to Warner, the teller completed the deposit and then filed a SAR, one of hundreds of thousands, if not millions, banks file every year to FinCEN. Here is what a SAR reporting form looks like. 7/

When the IRS agent (Steve Berryman) got the SAR, he knew he had something and so he went to work. He went to the branch and interviewed the teller. He subpoenaed all Daryan Warner's other deposits. He got deposit tickets. Camera footage from ATMs. Airline itineraries. 8/

He pulled the same data on Daryl Warner as well. What emerged from all the gumshoeing was a clear picture of organized money laundering activity, specifically a practice known as "structuring" or "smurfing" in which many deposits under $10K are made into various accounts. 9/

The Warner brothers were depositing dollars, euros, rubles, and pounds at several banks and in branches all over the country. They'd fly from Miami to Vegas to NY for little other apparent purpose than making $9,000 cash deposits. Gathering all the evidence was a big job. 10/

But eventually there was enough info, and on November 20, 2012, Berryman swore out a criminal complaint against Daryan and Daryll Warner in Brooklyn. And then he flew to Miami with some FBI agents and arrested them. In front of their father, who was visiting from Trinidad. 11/

The complaint, in full, is meticulous. Every deposit was reviewed. It took roughly 14 months for this single investigation, based on one SAR, to reach charging stage, and both Warner brothers pleaded guilty. 12/

But it's important to note that it was the IRS reaching out to FinCEN seeking info that led to the convictions. Otherwise, it seems fair to assume that FinCEN would have done nothing with the single, critical SAR. 13/

Like millions of others, it would have just sat there, which is a critical point made by my colleagues @JasonLeopold @a_cormier_ @TomBWarren @Richard_AHolmes @jsvine @jtemplon @scottpham and all the folks @ICIJorg in their outstanding work on this topic. 14/

(Finally, if you want more detail on the FIFA investigation, or want to hear the story of Jack Warner watching his own sons get arrested, feel free to check out my book, Red Card, which explains how heavily the landmark case hung on money laundering. 15/) https://www.amazon.com/Red-Card-Whistle-Biggest-Scandal/dp/150113390X