Thursday, March 11, 2010

Our Top Five Unsuspicious States

Or is it our bottom five suspicious states?

FinCEN's "By The Numbers" report from January shows SAR-SF reporting summary totals from 2003 through June 2009. SAR-SF's are forms filed by securities brokerage firms and other non-depository institutions (non-banks). Here are the states with our nation's most trusting brokers (or most honest investors, depending on how you look at it), in order of fewest SAR-SF's filed since 2003:
  1. Alaska (!! How can they be that unsuspicious? Is there no check fraud, mail fraud, insider trading, or at very least, forgery, taking place up there? I'm suspicious...)
  2. Wyoming (1 SAR-SF filed since 2003 for check fraud. I hope it was against Cheney.)
  3. Hawaii (5 total: 1 for embezzlement and the others for other... you can't trust surfers...or maybe you can...)
  4. Rhode Island (twice the population of Wyoming living on 1/100 the land mass and only 4 more SAR-SFs? Obviously the most trusting lot on the East Coast. We should all move there.)
  5. South Dakota (Hmmm. How can they have filed 10 SAR-SF's to date more than Alaska, a state full of corrupt politicians and crazed hunters with helicopters? I'm still suspicious...)
I skipped non-states in my list, such as District of Columbia. DC beat SD with fewer SAR-SFs. WHAT?? Wait, DC has 600,000 people living there, most of them working for the government (okay, that might not be technically true), and these numbers make it look like Mayberry RFD. What do these numbers mean: are there no BD's, CPO's, CTA's, FCM's, IA's or other such financial institutions in DC, resulting in the dearth of filings? Or is everyone in DC really, really honest, their activities arousing no suspicions? (Uh, did I just say that?) Or does everyone in DC have each other's backs?--oh wait, I may have stumbled onto something. Hmmm. Again, I'm suspicious.

Oh, in case you're wondering, NY has the highest number of SAR-SF's filed to date. Ho hum.

And once again, the type of suspicious activity near the bottom (ranked 20 out of 21) is--yes, that's right--Terrorist Financing! The reason you're all in this mess called AML compliance represents less than 1% of all SAR-SF's filed to date--206, to be exact. The SAR Activity Review offers a lot of information on the growth of mortgage loan fraud as a reported event, but nothing on how all these SAR's are fighting terrorism. But then again, we now know that it's not about that anymore.

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As for bankers and their customers: completely different story. Alaska redeems itself in that race, with the second highest number of SAR's filed from 1996 through June 2009. Now that's what I'm talkin' about! Wyoming is still pretty unsuspicious, ranking 48th out of the 50 states (but that doesn't absolve Cheney of my personal suspicion); and surfers, believe it or not, turn out to not be so trustworthy (Hawaii ranks 30th). South Dakota (23rd) has thousands more SAR filings by banks, but still looks good compared to Alaska; and lastly, I still think it's a good idea to move to Rhode Island...38th of the 50 states.

The good news for New Yorkers is that California outdid them in the SAR's-filed-by-banks competition: CA has more than double NY's filings.

And yes, Terrorist Financing ranks equally low in these filings, just like with SAR-SF's: second to last with less than 1% of all filings. Sigh.

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Here are the links to my resources. I suggest you take a look, so you can glean useful information (as opposed to useless information like the kind I presented above). The last link is especially valuable for you AML Compliance Officers and auditors.

FinCEN's News Release on the Jan. 2010 By The Numbers Report

FinCEN's SAR Activity Review--By The Numbers Jan. 2010

FinCEN's SAR Activity Review, October 2009

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