The unchecked movement of dirty money involves narcotraffickers, smugglers and Ponzi schemers shift illicit profits beyond the reach of authorities, and despots and corrupt captains of industry swell their own ill-gotten fortunes and consolidate power, aided and abetted by the powerful and the banking system. Dozens of the stories documented during the FinCEN Files investigation trace money transfers like these, connecting foreign capital to companies that only exist on paper. The suspicious flow of money is made possible by globally operating banks, which so far appear to have felt little pressure to prevent such transfers.
The FinCEN Files are based on Suspicious Activity Reports (SARs). These are records of money movements that the banks themselves compile and submit to the US Department of the Treasury, when they suspect a possibly suspicious activity. A review of the files casts a disturbing spotlight on the complex trail left by nearly $2 trillion (€1.7 trillion) of suspicious funds being maneuvered around the globe — and on the role of banks.
"It isn't the criminals themselves that launder the money. So the banks have a really important role to play because they are the system by which that money is being moved from their country, to a nice, safe place," Graham Barrow, a money laundering expert.
The Suspicious Activity Reports (SARs) come from a small number of large banks: Deutsche Bank (982), Bank of New York Mellon (325), Standard Chartered Bank (232), JPMorgan Chase (107), Barclays (104) and HSBC (73). Together, these banks filed more than 85% of the SARs contained in the leak.
Dozens of prominent figures appearing in the documents read like a who's who of well-connected political insiders. They include Paul Manafort, the former Donald Trump campaign manager, who was convicted of fraud and tax evasion. JP Morgan reported that it moved money between Manafort and his associate shell companies as recently as September 2017, long after his ties to Russian-connected Ukrainian officials and suspected money laundering had been widely reported.
Often the person tied to a suspicious transaction was one step removed from the boldfaced name: a child, an associate, or the wife — as in the case of Atiku Abubakar. The former Nigerian vice president was indicted by a Nigerian Senate committee for diverting over $100 million from an oil development fund. Years after corruption allegations against her husband surfaced, Rukaiyatu Abubakar moved more than $1 million of her husband's money through Habib Bank to a company in the United Arab Emirates to buy an apartment in Dubai.
Some, like Iranian-Turkish gold trader Reza Zarrab, appear in connection to sanctions violations. In 2017, Zarrab pled guilty to charges of fraud, money laundering and evading US sanctions on Iran before a US Federal District Court in New York. The SARs in the FinCEN Files document how he and his network transferred funds through US-based financial institutions. In June 2016, three months after Zarrab was arrested on his way to Walt Disney World, Standard Chartered Bank filed a series of Suspicious Activity Reports on a decade of bank transactions involving Zarrab and his network. The following October, Standard Chartered filed another report, listing $133 million worth of transactions made by entities the bank had tied to Zarrab's network.
A probe by US and New York banking regulators found the Deutsche Bank had moved $10.9 billion (€9.2 billion) on behalf of Iranian, Libyan, Syrian, Burmese and Sudanese financial institutions sanctioned by the US between 1999 and 2006. The bank was accused of carrying out transactions for its customers using "non-transparent methods and practices" to disguise its actions.