TopMortgage Compliance Update (1)
 

May 17, 2013    

 


FinCEN: Accountant and Elder Abuse




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Greetings!

We have been keeping track of FinCEN's SAR Activity Review - Trends, Tips & Issues virtually from its inception.

In its just issued May 2013 report, FinCEN provides new information regarding two areas of importance:

1) The Suspicious Activity Report (SAR) filing patterns related to elder financial exploitation before and after the publication of FinCEN's Advisory to Financial Institutions on Filing Suspicious Activity Reports Regarding Elder Financial Exploitation ("Advisory"), in February 2011, and

2) An analysis of trends related to SAR filings involving accountants and involving insider abuse within depository institutions.

In this newsletter, I would like to provide you with some insights regarding each of these areas of concern reviewed in the FinCEN report, with a brief review of elder abuse trends and a much more extensive review of suspicious financial activity involving accountants.

Best wishes,
Jonathan
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IN THIS ARTICLE

Elder Abuse - Trends 
Accountant Abuse - The Gatekeeper 
Sampling the Data 
Separating the Wheat from the Chaff 
Accountants Abuse - Trends 
Conclusion 
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The Activity Review - Trends, Tips & Issues
Issue 23
May 8, 2013
  
BSA Advisory Group
Financial Crimes Enforcement Network
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