# FinCEN Guidance, Statement of Interest filed by the United States in the case of Wuliger v. Office of the Comptroller of the Currency, 2005-04-05: Statement of Interest filed by the United States in the case of Wuliger v. Office of the Comptroller of the Currency

> Federal · Agency guidance · In force

URL: https://www.frixlaw.com/law-library/statutes/FINCEN_GUID_STATEMENT_INTEREST_FILED_UNITED_STATES_CASE_WULIGER_V

## Section

- **Citation:** FinCEN Guidance, Statement of Interest filed by the United States in the case of Wuliger v. Office of the Comptroller of the Currency, 2005-04-05
- **Heading:** Statement of Interest filed by the United States in the case of Wuliger v. Office of the Comptroller of the Currency
- **Jurisdiction:** Federal
- **Kind:** Agency guidance
- **Status:** In force
- **Text as of:** August 14, 2026
- **Source:** Compiled text
- **Location:** FinCEN Guidance (alerts, advisories, notices, bulletins, fact sheets) / Statement of Interest filed by the United States in the case of Wuliger v. Office of the Comptroller of the Currency

## Text

~ THE UNITED STATES DISTRICT COURT
NORTHERN~ISTRICT OF OHIO
EASTERN DIVISION
WILLlAfv1 T. WUUGER, RECENER,
Case No. 1:O5CYOIO8
PJaintiff,
U.S. District Judge David A. Katz
vs,
OFFICE OF THE COMPTROLLER
OF THE CURRENCY,
~ ~,
Defendants.
STATEMENT 0
ES
Pursuant to 28 V.S.C. § 517,1 the United States Department of Justice, by its undersigned
attorneys, hereby submits this Statement of Interest to protect from unauthorized disclosure aT).Y
Suspicious Activity Reports (SARs) submitted by financial institutions under the Bank Secrecy Act, 31
V.S,C. §5318(g)(1), from unauthorized discl.osure.,2
I 28 U.S.C.§ 517 provides in pertinent part: "Any ofticer of the Department of Justice(] may
be sent by the Attorney Genera] to any. ..district of the United States to attend to the interests of the
United States in a suit pending in a court oitheUnited States[.l"
2 The Board of Governors ot' the Federal Reserve, the Office of Thrift Supervision, the Pedttal
Deposit Insurance Corporation, and the National Credit Union Administration concur with the
arguments set forTh herein.

Background
'FinCEN") is a bureau of the United States
The Financial Crimes Enforcement Nenvork
Department of the Treasury, whose mission is to safeguard the financial system from the abuses of
financial crime, including teITorist financlPg, money laundering, and other illicit activity- Pursuant to a
delegation of authority fIorn the Secretary of the Treasury, FinCEN administers the recordkeeping,
reporting, and anti-money laundering program requirements of the Bank Secrecy Act, 31 'U.S.C
§ § 5311, g.t. ~,
and maintains a government-wide data access service that includes reports collected
..
under this authority. ~ 31 V.S.C. § 310
This litigation involves an attempt by a private party to compel FinCEN's fellow Treasury
agency. the Office of the Comptroller of the CulTcncy ("OCC")
dkeeping,
reporting, and anti-money laundering program requirements of the Bank Secrecy Act, 31 'U.S.C
§ § 5311, g.t. ~,
and maintains a government-wide data access service that includes reports collected
..
under this authority. ~ 31 V.S.C. § 310
This litigation involves an attempt by a private party to compel FinCEN's fellow Treasury
agency. the Office of the Comptroller of the CulTcncy ("OCC"). to provide him with the most sensitive
type of report collected under the Bank Secrecy Act -the Suspicious Activity Report ("SAR";
The
Bank Secrecy Act provides specific limits on who may have access to any such reports collected under
its authority (generally, certain govemment agencies) aJ1d the use to which any such reports may be put
(criminal. tax, regulatory, and counter-tenorism). The Bank Secrecy Act extends special confidentiality
protection to SARs 3JId even to the fact that one has been filed. Under this authority, FinCEN, the
OCC, and the four other federal banking regulators al] have promulgated regulations strictly protecting
The complaint by its very nature calls into question
the confidentiality of these highly sensitive reports.
FinCEN's SAR regulations, and places at risk one of the pillars of the Suspicious Activity Reporting
system -its confidentiality. The United States, therefore, has an interest in protecting the SARs against
unauthorized disclosure, as set forth in the Bank Secrecy Act.
2

Plaintjff in this action seeks declaratory and injunctive relief compelling the OCC to provide him
with SARs, documentary material sl,lpporting any SARs, and any related information pertaining to
persons and entities allegedly involved in a viatical fraud scheme. The issue presented by the OCC's
entitled to such infornlation, may nonetheless compel its production despite the statutory and regulatory
prohibitions on its disclosure
claratory and injunctive relief compelling the OCC to provide him
with SARs, documentary material sl,lpporting any SARs, and any related information pertaining to
persons and entities allegedly involved in a viatical fraud scheme. The issue presented by the OCC's
entitled to such infornlation, may nonetheless compel its production despite the statutory and regulatory
prohibitions on its disclosure.
Statement of Facts
The United States adopts, and hereby incol1>°rates by ref(trence, the statement of facts from
the OCC's brief in support of its motion to dismiss or, in the alterative, for SillIlInary judgment.
Summary of Argument
Plaintiff in this action may not compel the production ofSARs, or even the acknowledgment of
The Bank Se{;recy Act authorizes FinCEN (as the Secretary of
their existence or non-existence.
Treasury's delegee) to require financial institutions to file reports, including reports of suspicious activity,
The Act further authorizes FinCEN to
for regulatory, tax, criminal, and collnter-teITorism purposes,
provide these reports to certain government agencies, to maintain them in a govenunent-wide data
access network, and to administer ti!le network according to applicable legal guidelines and policies,
Plaintiffs demand does not fall within these legal requirements.
SARs, moreover, are entitled to additional protection from disclosure. Financial institutions that
file them are statutorily prohibited irom disclosing to anyone involved in the transaction that the
transaction has been reported, Pursuant to this authority, FinCEN, the OCC, and the other federal
3
cable legal guidelines and policies,
Plaintiffs demand does not fall within these legal requirements.
SARs, moreover, are entitled to additional protection from disclosure. Financial institutions that
file them are statutorily prohibited irom disclosing to anyone involved in the transaction that the
transaction has been reported, Pursuant to this authority, FinCEN, the OCC, and the other federal
3

other than appropriate law eMorcement and regulatory agencies of the filing, Courtsna*~upheld these
regulations as reasonable interpretations oithe statute because disclosure, for example in litigation,
makes it more likely that the persons invdlvedin the transaction will be notified of thefi]m~,iA
derogation of the. Att!
In an a~pt
tOiend...rontllis prohibition, plaintiff has sought to compel
disclosure fromagovemmental agency -the OCC. But that disclosure, too, is prohibited. The Bank
Secrecy Act forbids governmental offic;:ials from making such disclosure, W11essthedisclo$~e is
neces5~ to fulfill their official duties. Plainly, the fact that a plaintiff might find an SAR (or the fact of its
existence or nonexistence) useful to its case has no bearing on the official need for a governnlental
official tod1scloSe it. Were it otherwise, the disclosure prohibition would be rendered meaningless
Congres$did not enact the Bank Secrecy Act to provide tools for civil discovery, and there is
no injuStice in honoring that choice. As FinCENiiflhe OCC, and the courts have noted in:tbe past, the
disclosure prohibitio!on
SARs doe~ not extend to the underlying transactional documents (such as
accoWlt records), and plaintiffs are free to seek such documents, question witnesses about them, and
ultimately,
to argue the inferences therefrom to the ultimate trier of fact. Accordingly, the OCC's
Imotion
to dismiss or, in the altem~tive, for summary judgment should be granted
ARGUMENT
A
past, the
disclosure prohibitio!on
SARs doe~ not extend to the underlying transactional documents (such as
accoWlt records), and plaintiffs are free to seek such documents, question witnesses about them, and
ultimately,
to argue the inferences therefrom to the ultimate trier of fact. Accordingly, the OCC's
Imotion
to dismiss or, in the altem~tive, for summary judgment should be granted
ARGUMENT
A.
The Statutoa and Regullitorv Framework
Congress enacted the Bank Secrecy Act in 1970 to authorize the Secretary of the Treasury to
require reporting and recordkeeping deemed to have a "high degree of usefulness" to governmental
Icriminal, tax, or regulatol)' investigations or proceedings. ~
31 V.S.C. §,3.11 (declaration of
Ii

purpose).) The implementing regulations, found at 31 C.F.R. Part 103, create a system of reporting
and recordkeeping obligations intended to provide a paper trail to enable government investigators to
:ollow the money. See gen~ra!ly Ca.Jifomia Bankers Ass'n v. Shul{~, 416
S. 21, 26-30 (1974)
Section 5319 of the Bank Secrecy Act requires the Secretary to provide infonnation contained in Bank
Secrecy Act reports to a governmental agency upon request.4 Implementing regulations prescribing
those governmental entities entitled to seek access to Bank Secrecy Act infom1ation, and the methods
for requ,~sting it. are found at 31 C.F .R. § 103.53,
The initial focus of the Bank Secrecy Act was the tracking of large currency transactions, and
the initial regulations required reporting of various transactions
over $10,000 in currency. ~
3
(
,R.
§ 103.22 (cun-ency transaction reports); 31 C.F.R. §lO3.23 (reports of transportation of
currency and monetary instruments); 31 C.F.R. § 103.24 (reports of foreign financial accounts).
Congress expanded this focus in 1992 with the passage of the Annunzio- Wylie Anti-Money Laundering
Act, Pub. L. 102-550, Title XV, § 1517(1992), which added 31 V.S.C. § 5318(g) to the Bank
Secrecy Act
cy. ~
3
(
,R.
§ 103.22 (cun-ency transaction reports); 31 C.F.R. §lO3.23 (reports of transportation of
currency and monetary instruments); 31 C.F.R. § 103.24 (reports of foreign financial accounts).
Congress expanded this focus in 1992 with the passage of the Annunzio- Wylie Anti-Money Laundering
Act, Pub. L. 102-550, Title XV, § 1517(1992), which added 31 V.S.C. § 5318(g) to the Bank
Secrecy Act. This provision authorizes the Secretary of the Treasury to "require any financial
institution, and any director, officer I cmployee or agent of any financial institution, to report any
Recognizing both the
suspicious transaction relevant to a possible violation of law or regulation
3 ill the USA Patriot Act of2001, Congress amended 31 U.S.C. 5311 to include-as a purpose
of the Bank Secrecy Act lithe conduct of intelligence or counterintelligence activities, including analysis,
to protect against international teITorisffi." Pub. L. 107-56, Title ill, Sec. 358(a) (October 26,2001).
4 The USA Patriot Act of2001 amended this provision to include within the defmition of
((agency" a self-regulatory organization registered with the SecuritIes and Exchange Commission or fue
Cornn10dities Futures Trading Commission. Pub. L. 107-56, Title III, section 358(c) (October 26,
2001).

sensitive nature of the infonnation and fue need to encourage the filing of these reports by the provision
of appropriate legal protection, Congress included in the new statutory authorization two important
First, it provided that filers and their agents "may not notify any person involved in the
provisions.
transaction that the transaction has been reported." 31 V.S.C. § 5318(g)(2)(A)(i)
2001).

sensitive nature of the infonnation and fue need to encourage the filing of these reports by the provision
of appropriate legal protection, Congress included in the new statutory authorization two important
First, it provided that filers and their agents "may not notify any person involved in the
provisions.
transaction that the transaction has been reported." 31 V.S.C. § 5318(g)(2)(A)(i). Second, it
provided a "safe harbor" for filers aJld their agents, under which they "shall not be liable to any person
under any law or regulation of the United States [or] any constitution, law or regulation of any State
for such~ disclosure or for any failure to provide notice of such disclosure to the person who is the
subject of such disclosure or to any other person identified in the disclosure." 31 U.S.C
§ 5318(g)(3)(A),
In the AnnWlZio- Wylie Act, Congress f~er
instructed the Secretary to designate a single
agency or official to whom SARs sltall be made. ~ 31 V.S.C. § 5318(g)( 4). The Secretary
designated FinCEN.S In 1996, FinCEN, along with the five federal banking regulators,
promulgated Suspicious Activity Reporting roles for banks.6 The rule requires that a bank file an SAR
with FinCEN on any transaction conducted or attempted to be conducted through it, which aggregates
at least $5,000, and which the bank knows, suspects or has reason to suspect: (i) involves funds
5 The Secretary's delegation of Bank Secrecy Act authority to FinCEN is now embodied in
Treasury Order 180-01 (available at Treasury's website, www.ustreas.gov).
6 See 31 C.F.R. 103.18. The five federal banking regulators are: the Office of the Comptroller
of the CUITency, the Board of Governors of the Federal Reserve, the Federal Deposit msurance
Corporation, the Office of Thrift Supervision, and the National Credit Union Administration. Each
agency promulgated a separate rule, although the rules are substantially similar, with the main difference
being special treatment for insider abuse in the banking agency rules
e: the Office of the Comptroller
of the CUITency, the Board of Governors of the Federal Reserve, the Federal Deposit msurance
Corporation, the Office of Thrift Supervision, and the National Credit Union Administration. Each
agency promulgated a separate rule, although the rules are substantially similar, with the main difference
being special treatment for insider abuse in the banking agency rules. More recently, FinCEN has
issued suspicious actjvity reporting rules for money services business; broker-dealers in securities; and
commodities futures commission merchants, all with the same disclosure restrictions discussed herein.
6

derived from illegal activities; (ii) is desigped to evade Bank Secrecy Act requirements~ or (iii) has no
business or apparent lawful purpose and i~ not the sort in which the 'customer should no~ally be
expected to engage and the bank knows o~ no reasonable explanation for the transaction, 31 C.F .R.
§ 103. 18(a)(2).
FinCEN's regulation places additj~nal disclosure restrictions on SARs. Specifically, ilie rule
requires that "any person subpoenaed or ofheI\vise requested to disclose a SAR or the infoffi1ation
contain...ed
in a SAR, except where such difclosure is requested by FinCEN or an appropriate law
enforcement agency or bank supervisory ~ency, shall decline to produce the 8AR or to provide any
infonnation that would disclose that a S4 has been prepared or filed," 31 C.F.R.§ lO3.18(e). The
OCC's suspicious activity reporting regul4tion.contains
similar language, ~ 12 C.F.R. § 21.11(k).
The USA Patriot Act codified Fin4EN's rolc in administering the collection, use, and
dissemination of Bank Secrecy Act repo~. ~
31 U.S.C. § 310. FinCEN is charged with
maintaining a government-wide data netwprkthat includes Bank Secrecy Act reports, 31 U.S.C.
§ 310(b)(B)(1); analyzing ana disseminatifg the material for certain purposes, 31 V.S.C
contains
similar language, ~ 12 C.F.R. § 21.11(k).
The USA Patriot Act codified Fin4EN's rolc in administering the collection, use, and
dissemination of Bank Secrecy Act repo~. ~
31 U.S.C. § 310. FinCEN is charged with
maintaining a government-wide data netwprkthat includes Bank Secrecy Act reports, 31 U.S.C.
§ 310(b)(B)(1); analyzing ana disseminatifg the material for certain purposes, 31 V.S.C. § 310(b)(C);
and, as the Secretary's delegee, prov.iding rppropriate standards and guidelines for who is to be given
access to the infonnation and the US~S to ,hich it may be put, 31 V.S..C. § 31 O( c )(2).
At the san1e time, Congress stren~hened the SAR confidentiality provisions, adding new
subsection 5318(g)(2)(A)(ii), which.provifes that "no officer or employee of the Federal Govenunent
or of any State, local, tribal, or territorial ~overnment within the United States, who has any knowledge
that such report was made may disclose tol any person involved in the transaction that the transaction
has been reported, other than as necessarylto fulfill the official duties of such officer or employee.
..
7

Consistent with its regulatory interpretation of § 5318(g)(::;'.)(A)(i), FinCEN interprets this provision to
prevent governmental officers and employees from makjng disclosures likely to lead to a disclosure to a
person involved in a reported transaction, with the added qualification of official necessity. FinCEN
interprets official necessity to mean necessary to accomplish a govenunental purpose entrusted to the
officer or employee, for example, disclosure at trial required by statute (such as the Jencks Act), or the
U.s. Constitution (such as exculpatory evidence),
B
ludic1
alified Privile
'cious Activit R arts
Not long after Suspicious Activity Reporting requirements became effective, plaintiffs in civil
litigation sought to obtain such reporrts and to hold banks liable for filing (or not filing) them
officer or employee, for example, disclosure at trial required by statute (such as the Jencks Act), or the
U.s. Constitution (such as exculpatory evidence),
B
ludic1
alified Privile
'cious Activit R arts
Not long after Suspicious Activity Reporting requirements became effective, plaintiffs in civil
litigation sought to obtain such reporrts and to hold banks liable for filing (or not filing) them. The
Second Circuit addressed the interplay between the SAR confidentiality provision aIld the safe harbor
provision in Lee v.Banker's Trust CIP., 166 F.3d 540 (2d Cir. 1999), affinning the djstrict court's
dismissal of a defamation claim against a bank based on its alleged filing of an SAR concerning the
plaintiff. Noting the confidentiality provision of the Federal Reserve's regulation, 12 C.F.R
§ 20S.20(k), which is identical to that ofFinCEN a11d the OCC, the court stated:
Our conclusion based on the language ofllie Act [that the filing of the SAR is protected
by the safe harbor] is bolstered by a common sense appraisal of the safe harbor's place w'ithin
the Act. Financial institutions ar~ required by law to file SARs, but are prohibited from
disclosing either that an SAR has been filed or the infom1ation contained therein. See 12
C.F.R. 203.20(k) (1998). Thus, even in a suit for damages based on disclosures allegedly
made in an SAR, a financial institution cannot reveal what disclosures it made in an SAR, .Q!
even whethe(jt filed an SAR at all.
166 F .3d at 544 (emphasis added) This reasoning has been followed by a number of lower courts
faced with motions to compel the production ofSARs. In Weilv: Longl§land Savings Bank, 195 F.
Supp. 2d 383, 389 (E.D.N.Y. 2001). (he court found that the Suspicious Activity Reporting rules
8
a financial institution cannot reveal what disclosures it made in an SAR, .Q!
even whethe(jt filed an SAR at all.
166 F .3d at 544 (emphasis added) This reasoning has been followed by a number of lower courts
faced with motions to compel the production ofSARs. In Weilv: Longl§land Savings Bank, 195 F.
Supp. 2d 383, 389 (E.D.N.Y. 2001). (he court found that the Suspicious Activity Reporting rules
8

prohibit disclosure of SARs or their content, and that the confidentiality privilege created by the statute
and implementing regulations is not qualified and is not subject to waiver. Accor~ Grego~ v. Bank
One. Indiana. N.A., 200 F. Supp.2d lOOO, 1003 (S.D. Ind. 2002) ("There is no provision in the [Bank
Secrecy] Act or the Rule allowing a court-order exception to the unqualified privilege"); Cotton v.
Private Bank and Trost Co., 235 Po Supp.2d 809,815 (N.D. Ill. 2002); Whitne:y:~atiQnal Bank y.
'.
Karam, 306 F. Supp.2d 678,682 (S.D. Tex. 2004).7
Co~s have detennined that, although the statute specifically bars the disclosure of the SAR only to
the persons involved in the transaction, the regulations forbidding any disclosure are authorized by the
statute because a disclosure in litigation would make it more likely that the report would be disclosed to
the persons involved in the transaction. ~,~,
Q.QllQ.D.,
235 F. Supp.2d at 815 ~
In_re Bankers
Trust Co., 6.1 F.3d 465,469 (6th Cir. 1995), and Chevron USA. Inc. v. National Resources Defense
Council, 467 U.S. 837 (1984) ("federal regulations should be adhered to and given full force and effect
whenever possible"), As Cotton noted, a judicially-created exception to the non-disclosure rule would
harm the interests the BaI1k Secrecy Act was intended to promote, by compromising an ongoing
investigation, revealing methods by which banks are able to detect suspicious activity, deterring banks
from filing by subjecting SAR preparers to retaliation by customers, and harming the privacy interests of
innocent third parties whose names n!lay appear in a report
tion to the non-disclosure rule would
harm the interests the BaI1k Secrecy Act was intended to promote, by compromising an ongoing
investigation, revealing methods by which banks are able to detect suspicious activity, deterring banks
from filing by subjecting SAR preparers to retaliation by customers, and harming the privacy interests of
innocent third parties whose names n!lay appear in a report. ~
Indeed, the hann from disclosure of
7 Although Cotton notes that in one Freedom of Infonnation Act case a portion of a SAR was
ordered to be produced, DuDre v. Federal Bureau ofmvestieation, 2002 U.S. Dist. LEXIS 9622 (E.D.
La. May 22, 2002), after defendant filed an appeal an~ obtained a stay from the court of appeals, the
plaintiff withdrew the request and the case was dismissed as moot. Although this information does not
appear in the subsequent history, it can be found in that court's electronic case docketing system.
9

an SAR was recognized to be so serious, and the law protecting it to be so clear, that the Florida Court
of Appeals issued the rarely granted writ of certiorari to vacate a discovery order issued by a state
court. ~Inj~mational
BankofMi~i
v. Sbinitzkv, 849 So.2d 1188,1191-93 (Fla. Ct. App. 2003)
As FinCEN and the regulators always have acknowledged and the courts have recognized,
however, this prohibition does not extend to underlying transactional documents relevant to a claim or
defense. Financial institution business records, such as account statements and wire transfer advices,
are discoverable
under the standards of the Federal Rules of Civil Procedure.
~,
li,
Whitney,
235
..
F. Supp.2d at 682-83; Cotton. 235 F. Supp.2d at 815-16. Plaintiffis free to seek such documents,
What he CaImot do is invade the confidentiality of the Suspicious Activity Reporting system jtself.
Perhaps recognizing the strength of this body of law, plaintiff has not sought SARs from banks, but
from one of their regulators
ndards of the Federal Rules of Civil Procedure.
~,
li,
Whitney,
235
..
F. Supp.2d at 682-83; Cotton. 235 F. Supp.2d at 815-16. Plaintiffis free to seek such documents,
What he CaImot do is invade the confidentiality of the Suspicious Activity Reporting system jtself.
Perhaps recognizing the strength of this body of law, plaintiff has not sought SARs from banks, but
from one of their regulators. If the confidentiality pTotections for SARs were held not to apply in such
circumstances, then they would be rendered meaningless; a plaintiff could always circwnvent these
protections by asking the government, rather than the filers, for the reports. The reports would then
routinely be obtainable in civil litigation. This \vouldyield the type of absurd result forbidden by the
principles of statutory construction. ~,U,.,
UnitedStatesv. X-Citement Video. Inc., 513 U.S. 64,
69-70 (1994).
Section 5318(g)(2)(B) of Title 31 clarifies that this is not the res'ult Congress intended. Rather,
government officials are subject to the same disclosure restrictions as filers, except willi respect to
disclosures necessary to the perfonn~ce of their official duties. There is no legal basis for finding that
disclosure of an SAR to a plaintiff in a civil lawsuit is necessary tQ the perfOmlance of a bank
regulator's official duties. Seeking a court order to convert such disclosure into an official duty is
10

bootstrapping in the extreme. Rather, this is a narrow category.- examples of necessary official
disclosures would include prosecutorial disclosures mandated by statute or the U.S, Constitution, such
as where a report may contain a statement of a government witness to be called at trialJ impeachment
material of such a witness, or materiil1 exculpatory of the defendant.
Plaintiff does not fall within the categories of persons entitled to disclosure of an SAR, nor does
private civil litigation constitute a p~itted
use under the Bank Sec.recy Act
andated by statute or the U.S, Constitution, such
as where a report may contain a statement of a government witness to be called at trialJ impeachment
material of such a witness, or materiil1 exculpatory of the defendant.
Plaintiff does not fall within the categories of persons entitled to disclosure of an SAR, nor does
private civil litigation constitute a p~itted
use under the Bank Sec.recy Act. SARs are not
discoverable in civil litigation, either from the filers or from the government agencies that regulate the
..
filers. In the Bank Secrecy Act) Congress carefully balanced the interests of the government users and
filers to craft a reporting system that would provide the appropriate incentive to encourage reports of
wrongdoing while protecting law enforcement confidentiality and individual privacy interests. These
interests also have been carefully ba]anced by FinCEN and the bank regulators in issuing and
interpre.ting the implementing Suspicious Activity Reporting regulations.
CONCLUSION
For the foregoing reasons, the United States respectfully requests that this Court protect against the
unwarranted disclosure of SARs sought by plaintiff.
Respectfully submltted,
PETER D. KEISLER
Assistant Attorney General
ARTHUR R. GOLDBERG
Assistant Branch Director
1

1st Herb~nE. Forr~st
HERBERT E. FORREST
Lead Attorney -Attorney to Be Noticed
Federal Programs Branch
Civil Division -Room 7112
U.S. Department of Justice
20 Massachusetts Avenue, N.W.
Washington, D"C. 20530
Telephone: (202) 514-2809
Facsimile: (202) 616-8470
herbert. forrest@usdoj.gov
D.C. Bar No. 4432
OF COUNSEL:
JUDITHR STARR
Chief Counsel
Financial Crimes Enforcement Network
P. O. Box 39
Vierma, Virginia 222183
Telephone: (703) 905-3534
Facsimile: (703) 905-3735
Attorneys for the United States
April 5, 2005
12

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- [FinCEN Guidance FIN-2006-G012 Frequently Asked Questions Conducting Independent Reviews of Money Services Business Anti-Money Laundering Programs](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN2006G012.md)
- [FinCEN Guidance FIN-2006-G013 Frequently Asked Questions Suspicious Activity Reporting Requirements for Mutual Funds](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN2006G013.md)
- [FinCEN Guidance FIN-2006-G014 Potential Money Laundering Risks Related to Shell Companies](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN2006G014.md)
- [FinCEN Guidance FIN-2006-G015 Frequently Asked Question Customer Identification Programs and Banks Serving as Insurance Agents](https://www.frixlaw.com/law-library/statutes/FINCEN_FIN2006G015.md)

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Source: Frix Law Library, https://www.frixlaw.com/law-library/statutes/FINCEN_GUID_STATEMENT_INTEREST_FILED_UNITED_STATES_CASE_WULIGER_V. Check the current official text before relying on it. Not legal advice.