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— CH. 1 · THE LEAKED DOCUMENTS —

FinCEN Files

~3 min read · Ch. 1 of 7
7 sections
  • On the 20th of September 2020, BuzzFeed News published a trove of financial records that had been leaked to them in 2019. The collection contained 2,657 documents from the U.S. Treasury's Financial Crimes Enforcement Network. These files included 2,121 suspicious activity reports covering over 200,000 transactions between 1999 and 2017. The total value of these transactions exceeded one trillion dollars across multiple global institutions. Journalists discovered that banks often filed alerts about potential crimes but took no action to stop them. This pattern suggested a systemic failure within the banking system itself.

  • BuzzFeed News shared the stolen data with the International Consortium of Investigative Journalists for analysis. Four hundred journalists from eighty-eight countries worked together to examine the files before their public release. The Miami Herald described these records as the most detailed U.S. Treasury documents ever leaked. Despite the massive scale, the leaked set represented less than 0.02% of all suspicious activity reports filed during that period. Investigators found that most reports were never read or acted upon by government agencies. The collaboration revealed how easily information could be hidden even when it was officially recorded.

  • Deutsche Bank accounted for sixty-two percent of the leaked filings in this investigation. The bank processed $1.3 trillion worth of suspicious transactions despite facing hundreds of millions in fines for violating sanctions. HSBC faced scrutiny for laundering money on behalf of drug cartels while under a deferred prosecution agreement. Barclays Bank facilitated transfers for Arkady Rotenberg, a close associate of Vladimir Putin who is currently sanctioned. These institutions continued to operate globally even after regulators flagged their activities repeatedly. Critics argued that fines became merely a cost of doing business rather than a deterrent.

  • Malaysian businessman Low Taek Jho appeared in numerous transactions involving over $2.5 billion. He allegedly laundered proceeds from the government unit 1Malaysia Development Berhad through major international banks. Iranian-Turkish gold trader Reza Zarrab used complex schemes to evade economic sanctions on Iran. Former Donald Trump campaign manager Paul Manafort also appeared in the leaked records. Semion Mogilevich, an alleged Russian organized crime boss, was linked to these financial flows. These individuals utilized shell companies and offshore accounts to move illicit funds across borders without detection.

  • In Macau, sixty-two transactions totaling more than $68.2 million flowed between four local banks between 2000 and 2017. The Philippine remittance agents Philrem Service Corp and Werquick Inc sent over $1 billion of suspicious wires from 2012 to 2016. A consulting firm for the Tokyo Olympic 2020 bid committee paid $370,000 to Papa Massata Diack through a Singapore-based entity. In Ireland, an office in Riga helped clients establish secret accounts with Estonian and Latvian banks using UK LLP shell companies formed in the 1990s. These regional patterns showed how money moved through specific geographic hubs to avoid scrutiny.

  • Senator Elizabeth Warren pushed for her Ending Too Big to Jail Act bill following the disclosure. Senator Bernie Sanders stated that laundering practices were routine business practices on Wall Street. FinCEN announced on the 16th of September 2020 that they would be overhauling their money laundering programs. The European Parliament held a hearing on the 9th of October 2020 regarding the issues raised by the leak. Linda A. Lacewell noted that individual bankers are rarely held accountable when profits exceed fines. Regulators faced pressure to change how they handle financial crimes after public outrage grew.

Common questions

What are the FinCEN Files and when were they published?

The FinCEN Files refer to 2,657 financial documents leaked from the U.S. Treasury's Financial Crimes Enforcement Network that BuzzFeed News published on the 20th of September 2020.

How much money was involved in the suspicious transactions within the FinCEN Files?

The total value of over 200,000 transactions covered by these files exceeded one trillion dollars between 1999 and 2017.

Which bank accounted for the largest share of filings in the FinCEN Files investigation?

Deutsche Bank accounted for sixty-two percent of the leaked filings while processing $1.3 trillion worth of suspicious transactions despite facing hundreds of millions in fines.

Who leaked the FinCEN Files to journalists and what happened to them?

Natalie Mayflower Sours Edwards admitted to leaking the reports to BuzzFeed News in June 2021 and was sentenced to six months in federal prison for releasing other SAR documents.

When did regulators announce changes to their programs after the FinCEN Files leak?

FinCEN announced on the 16th of September 2020 that they would be overhauling their money laundering programs following public scrutiny of the data.

All sources

59 references cited across the entry

  1. 1webFY 2011 Budget-in-Brief10 February 2010
  2. 2webFY 2021 Budget-in-Brief10 February 2020
  3. 15webSEXTORTION: Dirty sources, dirty moneyStanley Buenafe Gajete — 2020-09-21
  4. 20webNy dokumentlekkasje om storbankerNTB — 2020-09-20
  5. 35newsHSBC Stock Hits 25-Year LowMargot Patrick and Frances Yoon — 2020-09-21
  6. 40newsHSBC moved scam millions, big banking leak showsFinCEN Files reporting team — 20 September 2020
  7. 41newsPutin associate 'moved millions' through BarclaysFinCEN Files reporting team — 20 September 2020
  8. 45newsSecret documents show North Korea laundering money through U.S. banksDan De Luce et al. — 20 September 2020
  9. 48webAdvance notice of proposed rulemaking (ANPRM) - Anti-Money Laundering Program EffectivenessFinancial Crimes Enforcement Network (FinCEN), Treasury — 17 September 2020
  10. 49newsFinCEN Files: Tracing the flow of dirty moneyPelin Ünker — Deutsche Welle — 20 September 2020
  11. 56newsFinCEN Files: Deutsche Bank tops list of suspicious transactionsPelin Ünker — Deutsche Welle — 20 September 2020
  12. 58webMaintaining the Confidentiality of Suspicious Activity ReportsFinancial Crimes Enforcement Network — 2010-11-23