The FinCEN Files Leak: The Key Takeaways


Leaked documents from the US Department of Treasury’s Financial Crimes Enforcement Network (‘FinCEN’), which involve $2 trillion of transactions, show how some of the world’s largest financial institutions have allowed criminals to launder money.

These leaked documents consist of Suspicious Activity Reports (‘SARs’) filed by banks and other financial services firms to FinCEN, in addition to other US government documents.


FinCEN is a bureau of the United States Department of the Treasury that is tasked with preventing money laundering, terrorist financing and many other financial crimes. It gathers SARs and makes them available to US law enforcement agencies and other nations’ financial services regulators.

A SAR must normally be reported by the Firm’s Compliance Officer within 60 days of initially detecting the suspected transaction.

The Leak

Known as the ‘FinCEN Files’, the leak is comprised of more than 2,100 SARs and shows that various financial institutions moved large sums of allegedly illicit funds over two decades, despite receiving warnings around the origin of the money. It serves to evidence the global financial corruption between banks and various organisations around the world.

Some of the findings are as follows:

  1. Ninety financial institutions were named including JPMorgan Chase & Co, Standard Chartered, BNY Mellon, HSBC and Deutsche Bank.
  2. Even after prosecution or fines being received for financial misconduct, various banks continued to move money for suspected criminals.
  3. Some financial services firms failed to report SARs until years after they had processed the cash.
  4. Large banks were moving money for organisations that were formerly accused of laundering money for terrorist organisations.
  5. Chelsea FC owner, Roman Abramovich, held secret investments in footballers through an offshore company.  
  6. Banks moved funds for companies that were registered in offshore locations, such as the British Virgin Islands and did not know the owners of the accounts.
  7. The UK is labelled a ‘Higher Risk Jurisdiction’ by FinCEN. This is because over 3,000 UK companies are named in the FinCEN files, which is more than any other country.

The Issue

The key issue shown here is that it should not be enough to file SARs and keep business as usual. If there is suspicion and certainly if there is evidence that criminal conduct is taking place, financial institutions should stop moving the cash and revisit their KYC efforts pertaining to the suspected individual or company. Whereas, further action needs to be carried out by the law enforcement, the industry should not be allowed to be indifferent to potential crimes as money laundering only covers up a bigger evil. Furthermore, the SARs, made by the banks and shared with the government, exposes weaknesses of banking precautions which can be easily  exploited by criminals.

One may draw a conclusion that by filing a notice of possible criminal activity taking place, the  financial institutions and its executives become, in practice, exempt from criminal prosecution for possible aiding criminal activity. We all know that this is not the intention of the lawmakers.

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