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Busines Executives for lational Security

Bringing business models to our nation's security


Memorandum October 18th, 2002

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To: From: Re:

All participants of the SunTrust/BENS Atlanta SAR Working Session Linda Millis, Vice President New Threats Initiative After Action Report

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Thank you for taking time out of your schedule to participate in our September 26th SAR working session in Atlanta. Your participation, along with the other members of the financial community who want to improve the Suspicious Activity Reporting process, was invaluable. Both the FinCEN representatives and the FBI told us afterwards that they felt it was a very worthwhile and effective meeting. We feel this signals great progress in the effort to promote and expand the full benefit of the relationship between the financial community, FinCEN and the FBI FRG.


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As promised, we are sending for your review a copy of our after action report on the September 26th SAR Working Session with the Financial Crimes Enforcement Network (FinCEN) and the FBI's Financial Review Group. It summarizes the points made during our discussion with David Vogt, David Gilles and Frank Waikart and includes several "Next Steps." Your comments and suggestions are especially welcome as we continue to work to improve the SAR process.


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If you have any questions, please call me at 202-296-2125. Thanks again for working with us and we hope to see you in the future.

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Linda Millis Vice President, New Threats


Blueprint for Change
Improving The Suspicious Activity Reporting Process
Challenges in the Current Reporting System ~ Our Work to Date
Over the last two years Business Executives for National Security (BENS) has engaged its members on a project to "Follow the Money" in an effort to improve the government's ability to identify, follow and disrupt financial activity related to terrorism. The Suspicious Activity Report (SAR) is the primary method for financial services firms to report activity that may be related to terrorism. BENS has convened business leaders from across the country and government officials in working sessions in New York, Atlanta, and San Francisco to discover what works and what doesn't work with the SAR process. Our goal is to identify shortcomings, propose meaningful changes and ultimately improve the way government collects, analyzes and disseminates critical financial information related to terrorism.

For more than 20 years, BENS members have been using their business experience and expertise to find practical solutions to pressing national security challenges. BENS approaches issues in a business-like way, not only proposing workable solutions but also working to get them implemented. Since December of 2000 BENS Financial Tracking Working Group has been working with government partners -- including the Treasury Department's Financial Crimes and Enforcement Network (FinCEN) and the FBI -- to identify ways to improve the Suspicious Activity Reporting (SAR) process. Over 75 business leaders across the country partnered with federal officials to examine the process and determine what specific steps could be made to make it an effective tool for identifying possible terrorist activity.

Getting It Done
Our working sessions, and this blueprint, represent only the first phase of our work. Much remains to be done. What follows are a number of specific steps that, once implemented, will substantially improve our nation's ability to more effectively use financial tools to fight the war on terrorism. BENS members are committed to continued work with our government partners to improve this process and win this war. To execute the changes recommended in this report, BENS recognizes that committed partners will be the essential element. We have had the good fortune of working with the leadership of FinCEN, the FBI and the Treasury Department, who have supported these efforts throughout this process. We look forward to building upon our initial work and beginning implementation of the recommendations that will make the process an important tool for national security.