What Does FinCEN’s 14th SAR Activity Review Tell Us About Fraud? There's A Lot Of It

The Financial Crimes Enforcement Network (“FinCEN”) today released its 14th edition of the “SAR Activity Review – By The Numbers,” which covers suspicious activity reports (“SARs”) filed in 2009. The report shows that the total number of all SARs filed by financial institutions declined from 1.29 million in 2008 to 1.28 million in 2009. This is the first time since 1996 that the total number of SARs filed declined over a one year period. That’s a bit of good news.

However, SARs reporting suspicious activity characterized as fraud grew in 2009. Reports of the categories of suspected Computer Intrusion, and Counterfeit Check, showed large double digit increases from the previous 12 months of reporting, increasing respectively 52 percent (!) and 12 percent.
 
Other changes where fraud was identified include:
 
·         Depository institution SARs identifying mortgage loan fraud rose four percent in 2009 compared to 2008.
·         Suspected incidents of credit card fraud increased five percent in 2009.
·         SARs filed by securities and futures firms, or SAR-SF, and characterizing the suspicious activity type as check fraud increased 15 percent in 2009.
·         SAR-SF filings characterizing the suspicious activity type as wire fraud increased 39 percent in 2009 over reports filed in 2008.
·         SAR-SFs also identifying mail fraud as the suspicious activity increased 23 percent and significant wire or other transaction without economic purpose increased 41 percent in 2009.
 
In all, 27 percent of the suspicious activity reported by depository institutions in 2009 was attributed to suspected fraud-related activities including check fraud, commercial loan fraud, consumer loan fraud, credit card fraud, debit card fraud, mortgage loan fraud, and wire transfer fraud. Mortgage loan fraud and check fraud remain the only two SAR characterizations that have experienced an increase every year since 1996.
 
Oh. There were two areas where the reported incidence of suspected fraud fell in 2009: The number of reports indicating consumer loan fraud fell in 2009, for the first time since 2000, down nearly 31 percent from the prior year; and SARs filed citing check kiting fell 23 percent in 2009.