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Title page
Contents
Highlights 2
Letter 7
Background 11
Money Laundering 11
Roles and Responsibilities under Bank Secrecy Act/Anti-Money Laundering Framework 13
Anti-Money Laundering Act of 2020 17
Financial Institution Representatives We Interviewed Suggested Enhancements to the SAR Process, Some of Which AMLA Implementation Could Cover 18
Representatives We Interviewed Identified Actions That Could Enhance Their SAR Processes 18
AMLA Implementation Could Address Some Suggestions Identified by Financial Institutions 26
FinCEN Has Not Provided Information in Full on Its Progress Toward Implementing AMLA 30
FinCEN Lacks Reliable Data on Law Enforcement Satisfaction with Its Products and Services 33
FinCEN Provides Several Products and Services to Help Support Law Enforcement 33
FinCEN Annually Surveys Law Enforcement Users on Satisfaction with Products and Services, but Surveys Have Methodological Weaknesses 38
Data on Outcomes of Federal Illicit Finance Investigations Do Not Provide a Full Picture of Total Outcomes 42
Federal Law Enforcement Agencies Collect and Report Data on the Outcomes of Their Illicit Finance Investigations 43
DOJ Datasets Provide a Multiagency View of Illicit Finance Investigation Outcomes 44
Comprehensive Data on the Outcomes of Federal Illicit Finance Investigations Are Not Readily Available 50
Conclusions 53
Recommendations for Executive Action 54
Agency Comments 54
Appendix I: Objectives, Scope, and Methodology 56
Appendix II: Transnational Criminal Organizations and Their Money Laundering Strategies 63
Appendix III: Outcomes of Federal Illicit Finance Investigations 75
Appendix IV: GAO Contacts and Staff Acknowledgments 88
Table 1. FinCEN Analytic Products 37
Table 2. Response Rates and Related Information for Selected FinCEN Customer Satisfaction Surveys, 2018-2022 39
Table 3. FinCEN's Performance Measures in Annual Performance Plan and Report, Fiscal Years 2018-2022 41
Table 4. Selected Examples of Illicit Finance-Related Performance Measures That Federal Agencies Use, Fiscal Year 2022 43
Table 5. Selected Examples of Performance Measures on Disruption and Dismantlement Used by Federal Agencies, Fiscal Year 2022 44
Table 6. Percentage and Number of Defendants in OCDETF Investigations Convicted of Financial Violations, Fiscal Years 2018-2022 49
Table 7. Statutes Used to Identify Relevant Cases in Data We Obtained 61
Table 8. Defendants Charged under Money Laundering-Related Statutes, Number and Percentage by Referring Agency, Fiscal Years 2018-2022 76
Table 9. Cases with Money Laundering-Related Charges, Number and Percentage by Referring Agency, Fiscal Years 2018-2022 78
Table 10. Defendants Convicted of Money Laundering-Related Charges, Number and Percentage by Referring Agency, Fiscal Years 2018-2022 79
Table 11. Cases with Money Laundering-Related Charges and Guilty Outcomes, Number and Percentage by Referring Agency, Fiscal Years 2018-2022 81
Table 12. Number and Total Value of Fines Associated with Money Laundering-Related Charges, by Fiscal Year, 2018-2022 82
Table 13. Number and Dollar Value of Seized Assets Associated with Money Laundering-Related Statutes, Fiscal Years 2018-2022 (Fiscal Year 2022 Dollars in Millions) 83
Table 14. Number and Dollar Value of Forfeited Assets Associated with Money Laundering-Related Statutes, Fiscal Years 2018-2022 (Fiscal Year 2022 Dollars in Millions) 84
Table 15. Number of Convictions in Closed OCDETF Investigations and Percentage Using Bank Secrecy Act (BSA) Information, Fiscal Years 2018-2022 85
Table 16. Number of Closed OCDETF Investigations Resulting in Disruption or Dismantlement of an Organization, Fiscal Years 2018-2022 86
Table 17. Number of Closed OCDETF Investigations and Percentage Resulting in Assets Seized and Forfeited, Fiscal Years 2018-2022 87
Figure 1. Stages of Money Laundering 12
Figure 2. Key Components of a Suspicious Activity Report (SAR) Monitoring and Reporting Framework 15
Figure 3. Number and Share of FinCEN Queries Conducted by Law Enforcement Agencies, Fiscal Years 2019-2022 35
Figure 4. Number of Defendants Who Had Been Charged under Federal Money Laundering-Related Statutes, by Disposition Status, Fiscal Years 2018-2022 46
Figure 5. Value of Seizures and Forfeitures in Money Laundering-Related Investigations in the Consolidated Asset Tracking System, Fiscal Years 2018-2022,... 48
Figure 6. Value of Seizures and Forfeitures in OCDETF Investigations, Fiscal Years 2018-2022, in Fiscal Year 2022 Dollars 50
Figure 7. Illustrative Example of Use of Client Trust Account to Launder Money 72
Figure 8. Number of Defendants Charged with Money Laundering-Related Offenses by State, Fiscal Years 2018-2022 77
Figure 9. Number of Defendants Convicted of Money Laundering-Related Charges, by State, Fiscal Years 2018-2022 80
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