Independent Investigations

CRI staff have assisted with and completed thousands of SAR investigations, providing us with a depth of knowledge that can improve your business and control your risk.

  • Example: A major international banking client discovered a customer’s suspiciously structured trade transactions between three Asian nations. The bank’s Compliance Office had advocated terminating the substantial client relationship based on the available information. Working closely with CRI staff in both New York and Asia, CRI determined that what appears at first blush to be illegal or suspicious conduct is in fact legitimate trade conducted in a manner to legally avoid certain import restrictions. The valuable customer relationship was retained.
  • Example: Federal regulators ordered a major New York bank to complete a retrospective SAR investigation of 18 months of possibly suspicious transactions. CRI staff negotiated an approach to the research, identified bank employees able to do the analysis, and prepared a work plan. The 1000+ SARs were filed on a timely basis, the government agency was fully satisfied, and a formal enforcement action was avoided.
  • Example: Major U.S. bank was accused of late SAR filing. CRI staff performed a forensic analysis of the 4 year-old case, its initial detection, investigation, and reporting. It was determined that the SAR was indeed filed in a manner consistent with “best practices” at the time, and that the bank had complied with the spirit of the Bank Secrecy Act (BSA). Criminal prosecution was avoided and the ambitious business plan was pursued successfully by the bank.