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Northern Ohio ACAMS
Chapter Newsletter
April 2016 (volume 1, issue 2)
The last Northern Ohio ACAMS event titled “Anatomy of a SAR” was held on Wednesday, March 9, 2016, at KeyBank on Tiedeman Road. A big thank you to our event sponsor RDC for providing us with the delicious food and beverages that allowed us the time to socialize together before the presentation.
The evenings presentation took us on a fascinating journey starting with a woman making unusual cash deposits at a bank branch to the ultimate arrest and prosecutions of multiple individuals associated with the Columbian Drug Cartel. The unveiling of how the special agents and analysts tracked the illicit activity, much of which was gathered through suspicious activity report filings, was informative from a business aspect as well as entertaining like a good mystery novel. What a great event!
We would like to thank the following speakers for taking time out of their busy schedules to be with us that evening.
Dirk Halscheidt, special agent for the Internal Revenue Service- Criminal Investigations (IRS-CI) and Head for the SAR Review Team
Brian Sallee, special agent for the IRS-CI Northern Ohio Money Laundering Task Force
Donald Heath, special agent for the U.S. Secret Service Northern Ohio Money Laundering Task Force
Tiffany Morgan, analyst for the IRS-CI Northern Ohio Money Laundering Task Force
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Welcome to our new chapter members
who joined during the first quarter of
2016:
Stacy Brashear – First Federal Bank
Kathleen Koch – First Federal Bank
Benjamin Pierce – First Federal Bank
Barbara Renfro – KeyBank
Amy Saade – Citizen’s Bank
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Dirk Halscheidt, Brian Sallee, Tiffany Morgan and Donald Heath
Bill Cloninger
Thank you to KeyBank for hosting the event!
As of April, the ACAMS NOH Chapter
has 160 members. Thank you for
your support!
Q: Who can join ACAMS NOH?
A: Anyone who is a National ACAMS Member.
Q: Can people who are not National ACAMS Members attend ACAMS NOH events?
A: Absolutely! Non-members only need to register through ACAMS.org or pay at the door the night of the event.
Q. Can I attend if I forgot to register online?
A: Yes, you may check in and pay at the door the night of the event. We do recommend registering in advance so that we can plan on enough food and beverage for all.
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Richard K. Gordon, director of the Financial Integrity Institute at Case Western Reserve
118 professionals were in attendance for the event
If you were not able to make it, you missed a great evening
The next ACAMS NOH Event will be in September. The date and location are yet to be determined.
For additional information on the latest Northern Ohio ACAMS events visit http://www.acams.org/acams-chapters/northern-ohio/
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Who is JoAnn Butler?
JoAnn Butler serves on the Executive Committee of the ACAMS NOH Chapter and was one of the founding members of the chapter. Butler joined PNC as part of the National City integration, where she served as the financial intelligence unit manager after years of experience in front-line management, financial analysis, investigations and business analysis. After joining PNC, she served in various roles with increasing responsibility. Until recently, she was the director of anti-money laundering (AML) operations with oversight for alert analysis, investigations and quality assurance processes. In 2016, she transitioned into AML risk management focusing on AML strategy in support of scenario tuning and other automated routines. Outside of work, Butler loves to read, go out to dinner with family and friends, spending time with her husband and two boys, and vacationing in new places.
Connect to
Northern Ohio ACAMS Chapter
We are on the web
http://www.acams.org/acams-chapters/northern-ohio/
Suspicious Activity Reports Document Bank Transactions on Behalf of Drug Trafficker
Investigators looking at a drug trafficking organization were helped by Suspicious Activity Reports (SARs) that a bank filed on an individual who laundered the illicit proceeds. Prosecutors charged that individual with hiding more than $800,000 belonging to an accused drug dealer involved in a murder-suicide. For several years, the bank meticulously filed SARs on the defendant, a long-time customer who suddenly changed his banking habits.
A Federal grand jury indicted the defendant on charges of conspiracy to commit money laundering and structuring transactions to evade reporting requirements, as well as requiring forfeiture of illicit proceeds. The indictment documents 140 instances of structuring. In addition, the indictment alleges that he either deposited or helped to deposit $843,000 from 2005-2008 in small amounts to hide those funds from the IRS.
Prosecutors said that the defendant conspired with a co-conspirator to hide money generated from illegal activity by buying five properties.
In a bizarre twist, the co-conspirator took a friend and co-worker hostage and then shot the friend and himself, according to police. The co-conspirator had initially claimed in telephone calls to the media and his lawyers that he was the hostage. Police said the co-conspirator shot the friend for talking to drug investigators, then set fire to the building. He then shot and killed himself.
As a result of the investigation, Federal investigators seized $210,000. Furthermore, the indictment sought forfeiture of more than $800,000 including 13 certificates of deposits, and several properties.
Investigators began looking at the defendant when they observed him with the co-conspirator, a known large-scale marijuana dealer. The
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In April, Bill Cloninger was awarded ACAMS AML Professional of the
Month. The ACAMS AML Professional of the Month is awarded to AML
professionals from both the public and private sectors for their
accomplishments and successes in the AML community. Bill was recognized
by his peers for his drive and passion in the anti-money laundering (AML) field. As this month’s winner, Cloninger will
be recognized on ACAMSToday.org and on ACAMS.org.
When notified of this honor, Cloninger
stated, “While I am surprised and thrilled by this unexpected honor, the credit, for any achievement I may have contributed toward, really should go to
defendant is a retired airline worker who also owned a bar, repaired houses, and sold real estate. After investigators identified the defendant, they queried him in the BSA database and found more than 45 records listing him as a subject, with most of the records filed during the timeframe of the alleged structuring.
Fourteen of these records were SARs. In addition, more than 30 Currency Transaction Reports (CTRs) document deposits greater than $10,000.
A bank began filing SARs on the defendant several years earlier. The bank noted that the defendant had been a customer for years, but tellers became increasingly suspicious of his transactions. For example, the defendant told tellers he did not like having his transactions reported to the government. In the initial SAR, the bank reported that the defendant came into the bank with the co-conspirator and cashed a check made out to the co-conspirator. A review of the defendant’s account revealed numerous checks made out to the co-conspirator for amounts ranging from $4,250 to $23,000.
The bank continued to file SARs periodically on the defendant. The bank notes that for months there would be very little suspect activity, while at other times the defendant would conduct multiple deposits that appeared to be structured to avoid reporting requirements. His transactions were indicative of those associated with drug trafficking; currency deposits in denominations as low as $10, but the total attempted deposits were as high as $115,000. The defendant frequently visited his safe deposit box before or after teller transactions.
Because of the unusual patterns of the defendant’s transactions, bank personnel surmised that he may be involved in gambling because many of the transactions occurred during basketball season. However, investigators allege that the suspicious transactions were drug related. The defendant is also listed on a Form 8300 for paying more than $15,000 in currency for a $51,000 Chevy Corvette.
The meticulously filed SARs helped investigators when they identified the defendant as an associate of the co-conspirator. With the bank’s help, law enforcement was able to analyze supporting documents and develop the structuring and forfeiture charges.
The case study was provided by:
Investigations Assisted by FinCEN Data - Posted July 2014 on https://www.fincen.gov/news_room/rp/sar_case_example_list.html?cati
d=00005
the ACAMS NOH Chapter Board of Directors, our partners at Notre Dame
College and Case Western Reserve University, Law enforcement and our corporate sponsors. It is a pleasure to be able to be associated with such an
outstanding group of professionals selflessly working to make the ACAMS
NOH Chapter the best it can be.”
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Have you or a colleague recently accomplished a business mild stone?
If so please let us know, we would love to celebrate your success in our
next newsletter. Email all information to
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Jody Nappier
Joann Butler
Frank Meister
John Moody
Bill Cloninger
Abbottabad, Pakistan – (Terrorist financing) The handwritten will of
Osama bin Laden reportedly included a fortune of “about 29 million
dollars” and directed that most of it should be spent on “jihad.” The will
was recently made public by the Office of the Director of National
Intelligence. From NPR: “The will was undated, but bin Laden said the
money was in Sudan, where he lived for several years in the 1990s. He
left Sudan for Afghanistan in 1996, just before the Taliban seized control
of the country and welcomed him…. Media reports over the years have
said that bin Laden was not able to take his fortune with him from
Sudan.” Per the article, bin Laden was concerned that one of his wives
would be implanted with a bugging or tracking device when she received
a dental filling in Iran. (Source: Greg Myre, “Osama Bin Laden's Will: $29
Million That Should Be Spent On 'Jihad,'” NPR, Mar. 1, 2016.
Manhattan, NY – (Money laundering, corruption, fraud) A recent in-
depth report by the New York Post discussed the mysterious lifestyle of
Jho Low, a purported 35-year-old Malaysian financier and agent, known
for spending large amounts of money at parties and conducting high-
value transactions for expenses such as condos and artwork: “Now the
mystery of Jho Low may have finally been solved, thanks to a scandal
that threatens the government of Malaysia and Wall Street titan
Goldman Sachs.” Per the article, federal investigators are conducting a
probe that may end up being “one of the largest money laundering
frauds in the world.” The article suggests that Low may be connected
with various funds that have led to political controversy in Malaysia.
From the article: “Now the feds are investigating if Jho Low’s wild
spending was courtesy of 1MDB, and if he was hiding assets or
laundering funds…. As for Jho Low, he’s no longer throwing money
around clubs. His bank accounts in various countries have been frozen,
and he is short for cash, according to the Sarawak Report.” (Source:
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Questions or corrections about this publication should be emailed to the “Newsletter Editor” at:
northernohiochapter.acams @gmail.com
Jennifer Gould Keil, “Mystery Malaysian high roller at center of global-
money laundering probe,” New York Post, Feb. 28, 2016.
A special thank you to FirstMerit Bank for sharing these articles
from their Monthly News Recap.
Would you like to become more involved with the ACAMS NOH Chapter? The chapter has many committees that you can become involved with such as communications, membership and event planning. We would also love to hear your ideas.
• Do you have a good idea for future events that you would like to discuss? We would be glad to hear your ideas and maybe you would even enjoy helping plan the event.
• Have you recently written an article on a BSA/AML/CTF topic? Maybe the article could be added to our quarterly newsletter.
• Do you have a subject-matter suggestion or know a speaker that would be a great presenter at one of our NOH Chapter events? If so, we would love to hear from you.
Please send your email suggestions to:
[email protected] and a board member will contact you for further information.
NOH ACAMS Chapter members should expect to receive a chapter
survey email via SurveyMonkey in the coming weeks. This short survey
will provide our chapter leadership with members’ thoughts and
comments on just a couple key forward-looking questions. The
information will be compiled and a summary will be provided in the
next edition of the Northern Ohio ACAMS Chapter Newsletter.
