On June 2, 2021, I joined FBI SA Dennis Lormel (ret.) in presenting an introduction to asset forfeiture for bank compliance officers entitled, “Webinar: Understand How Law Enforcement Uses Asset Forfeiture to Fight Criminals.” The program was sponsored by ACAMS and hosted by Scott Grob.
After explaining the basic “why” and “how” of asset forfeiture, my talk addressed several questions of particular interest to this audience:
- Why it is important for law enforcement agents to include the financial aspects of a case in their investigation from the beginning
- The importance of getting bank records, and getting them promptly and in electronic form
- How SARs and Currency Transaction Reports are used to start investigations and as historical records
- What authority the United States has to recover money from a foreign bank account
- What authority it has to issue a subpoena to a foreign bank
- What authority it has to seize or freeze money moving through the correspondent account of such a bank
- The rights of lien holders, and the right of a financial institution to take a setoff against the seized funds to satisfy the account holder’s debt.
This document is the text of my presentation: ACAMS – Intro to Forfeiture for Compliance Officers