Use of Additional Information in Suspicious Transaction Report

Types of Additional Information
Threshold-based transaction and other reports received by the FIU in accordance with AML/CFT legislation.
Government information (law enforcement, regulatory).
Commercially available information.

FIU Information Flow
DISSEMINATION
REPORTING
ANALYSIS
Banks
Securities
Dealers
Insurers
Casinos
Accountants
Lawyers
Other Persons
Suspicious
Transaction
Reports
Cash Transaction Reports
Electronic Transfer Reports
Cross-Border Cash Transaction Reports
Prosecutor’s Office
Law Enforcement Agencies
Other FIUs
FIU Database
Gov’t Databases
Data From Other FIUs
Other Data
Financial Intelligence
Reporting Entities
Reports
FIU Processes
Customers

Threshold-Based Reports Received by an FIU
Cash transaction reports.
Cross-border currency and/or financial instrument reports.
Electronic fund transfer reports.

Threshold Report Structure
Reporting sections include information on the:
reporting institution or border authority filing the report;
physical person conducting the transaction;
person (physical or legal) on whose behalf the transaction is conducted;
transaction;
account (except cross-border transaction reports).

Threshold Report Elements

Threshold Report Elements Continued

Threshold Report Elements Continued

Threshold Report Elements Continued

Threshold Reports in STR Analysis
— DISADVANTAGES —
Numbers of reports may be unmanageable.
Vast majority of reported activities are legitimate.
Analysis of them by themselves are of limited value.
Those related to ML/TF have recognizable patterns and characteristics and are reported as STRs in most cases.

Threshold Reports in STR Analysis
— ADVANTAGES —
Provide documented identifying data used by STR subjects.
Identify potential persons for the analytical cluster.
Uncover fund flows, transaction patterns, and conversion of funds relating to STR subjects.
Point to other sources of information from reporting institutions and partner FIUs.

Other Information Received by the FIU
FIU exchange information.
Sponsoring agency data for those FIUs housed in a larger organization.
FIU case data.
Supplemental STR background information from reporting institutions.

Types of Government Information
Investigation reports and criminal history records.
Company formation and registration records.
Border crossing records (arrival and departure).
Immigration records (visa and long-term admission to country).
Passport and drivers license records.
Vehicle, aircraft and boat registration.
Intelligence reports.

Sample Criminal History Information

Sample Border Crossing Information

Sample Driver’s License Information

Government Information in STR Analysis
— DISADVANTAGES —
Requesting/receiving information from other government agencies may be time consuming.
Information sharing restrictions may apply.
Information may require special handling.
Information may not be available electronically.

Government Information in STR Analysis
— ADVANTAGES —
Provides documented identifying data used by STR subjects.
Identifies potential persons for the analytical cluster.
Identifies assets, physical movements, criminal activity.
Reliability of information is of excellent quality.

Types of Commercial Information
Business Records
Identifying Data on Physical and Legal Persons
Property Records
Personal Property Records
Bankruptcy Records
Civil Case Documents
Judgment Records
Lien Records

Sample Information: Dun & Bradstreet Business Information Report
Gorman Manufacturing Company, Inc
492 KOLLER STREET
SAN FRANCISCO, CA 94110
This is a headquarters location. Branch(es) or division(s) exist.
Web site: www.gorman.com Telephone: [phone] Fax: [phone]
Chief executive: LESLIE SMITH, PRES
Stock Symbol GRM
Year started: 1965 Employs: 110 (100 here)
Financial statement date: DEC 31 2000
Sales F: 19,683,736 Net worth F: 3,160,644
History: CLEAR Financing: SECURED
SIC: 2752
Line of business: COMMERCIAL PRINTING
Business Summary

Sample Information: Dun & Bradstreet Business Information Report Continued
Headquarter
Gorman Manufacturing Company Inc. Foundation
San Francisco, CA 81-478-5122
Parent
Gorman Inc. Brothers Foundation
San Diego, CA 81-478-5122
Domestic Ultimate
Gorman International Inc. Brothers Foundation
San Diego, CA 81-478-5122
Global Ultimate
Gorman Co. Inc. Brothers Foundation
London, UK 81-478-5122
Corporate Family

Sample Information: Dun & Bradstreet Business Information Report Continued
The following information was reported 02/11/02:
Officer(s): LESLIE SMITH, PRESIDENT
KEVIN J HUNT, SEC-TREAS
Director(s): THE OFFICER(S) and Corporate details under investigation.
LESLIE SMITH born 1926. Graduated from the University of California, Los Angeles, CA, in June 1947 with a BS degree in Business Management. 1947-65 general manager for Raymor Printing Co, San Francisco, CA. 1965 formed subject with Kevin J Hunt. KEVIN J HUNT born 1925. Graduated from Northwestern University, Evanston, IL in June 1946. 1946-1965 was general manager for Raymor Printing Co, San Francisco, CA. 1965 formed subject with Leslie Smith.
COMMON STOCK: AUTH SHARES - 200
Corporate details under investigation.
Business started 1965 by Leslie Smith and Kevin J Hunt. 100% of capital stock is owned by the officers.
AFFILIATE
The following is related through common principals, management and/or ownership. Gorman Affiliate Ltd, San Francisco, CA, started 1965. Operates as commercial printer. Intercompany relations: None reported by management.
History

Sample Information: Dun & Bradstreet Business Information Report Continued
CORPORATE AND BUSINESS REGISTRATIONS PROVIDED BY MANAGEMENT OR OTHER SOURCE
The Corporate Details provided below may have been submitted by the management of the subject business and may not have been verified with the government agency which records such data.
Registered Name: Gorman Manufacturing Company, Inc. Business type: CORPORATION. Corporation type: PROFIT Date incorporated: MAY 21 1965 State of incorporation: CALIFORNIA Filing date: MAY 21 1965 Common stock Authorized shares: 200 Where filed: SECRETARY OF STATE/CORPORATIONS DIVISION, SACRAMENTO, CA
02/11/02 Description: Commercial printing specializing in advertising posters, catalogs, circulars and coupons.
Additional telephone number(s): Toll-Free 800 000-0000. Has 225 account(s). Net 30 days. Sells to commercial concerns. Non-seasonal. Employees: 110 which includes officer(s). 100 employed here. Facilities: Rents 55,000 sq. ft. in a one story cinder block building. Location: Central business section on well traveled street. Branches: Subject maintains a branch at 1 073 Boyden Road, Los Angeles, CA.
Business Registration
Operations

Sample Information: Lexis/Nexis Person Report

Sample Information: Lexis/Nexis Person Report Continued

Sample Lexis/Nexis Property Report

Commercial Data in STR Analysis
— DISADVANTAGES —
Reliability of data may be questionable.
Amount of data retrieved may prove unmanageable.
Information is sometimes provided by STR targets.
Incidence of false positives and name transliteration errors are not uncommon.

Commercial Data in STR Analysis
— ADVANTAGES —
Identifies relationships unavailable elsewhere.
Identifies assets, alternate identities, international locations of activity.
Points to other sources of information from partner FIUs.

Weighing Sources and Data
Reliability
reliable
usually reliable
unreliable
unknown reliability
Validity
confirmed
probable
doubtful
unknown validity