ABSTRACT
The Suspicious Activity Report (SAR) is easily the most valuable of the BSA forms. I make this claim with conˆdence because I’m very familiar with criminal cases that have been developed using several of the forms, and the SAR delivers the best bang for the buck. For one thing, there are a lot fewer SARs out there than the older Currency Transaction Report (CTR) form. With the computerized anti-moneylaundering programs in place at ˆnancial institutions, the CTRs get cranked out automatically, the software catching every instance in which the form is required and generating a report. The result is 15 million of these forms ˆled annually, a volume that makes analysis more difˆcult. The other problem with CTRs is that the vast majority of them represent perfectly legitimate cash transactions, such as grocery stores or other businesses making their bank deposits. Separating the gold from all of those 15 million straws is a problem.
