Read each statement, bank by bank.
Here are statements prepared by many of the world’s biggest financial institutions in response to questions about reporting in the FinCEN Files investigation. The investigation was based in part on 2,100 suspicious activity reports, or SARs, documents that banks file to the Treasury Department’s Financial Crimes Enforcement Network. By law, banks are not allowed to discuss or even acknowledge the existence of individual SARs.“This is not new information to us or our regulators.
"The goal of any financial crime compliance programme is to detect and prevent financial crime. One way we do that is through transaction monitoring and sanctions screening. Each month, we screen over 689 million transactions across 236 million accounts for signs of money laundering and financial crime. In addition, we screen approximately 131 million customer records and 40 million transactions monthly for sanctions exposures.
"2. Suspicious Activity Reports are a key part of the process by which law enforcement agencies gather evidence on possible financial crime matters. In common with other banks, we typically file thousands of SARs and other similar reports globally each year – this is a common and required practice in the financial services industry.
"5. If we conclude we have financial crime concerns, we take appropriate action and have done so in numerous cases over the years. As you will appreciate, terminating client relationships is not something we take lightly.
"8. But for the avoidance of doubt, we believe that we have complied with all our legal and regulatory obligations including in relation to U.S. sanctions. We would also refer you to the report by the U.S. Senate Permanent Subcommittee of Investigations entitled 'The Art Industry and U.S. Policies that Undermine Sanctions', published on 29 July 2020.
"As early as 2013, we discontinued our global banknote trading activities, i.e. the supply and safekeeping of banknotes, due to business policy considerations. In addition, we have significantly reduced the number of international partner and correspondent banks since 2015. Apart from income-, cost- and risk-related aspects, regulatory requirements played an important role in this context.
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