Federal Reserve Board of Governors

The Federal Reserve Board of Governors issues a non-routine supervisory letter to Federal Reserve banks, emphasizing the need to continue monitoring suspicious activity reports (SARs). The letter gives no explanation why it has been sent out at this particular time, but states, “Reserve banks must continue to conduct a thorough and timely review of all material SARs filed by supervised financial institutions in their districts.” It adds, “A periodic, comprehensive review of SARs will assist Reserve banks in identifying suspicious or suspected criminal activity occurring at or through supervised financial institutions; provide the information necessary to assess the procedures and controls used by the reporting institutions to identify, monitor, and report violations and suspicious illicit activities; and assist in the assessment of the adequacy of anti-money laundering programs.” [Spillenkothen, 8/2/2001] While the letter does not say if there are specific reasons why the banks should currently be watching for suspicious activities, William Bergman, an economist who works at the Federal Reserve Bank of Chicago from 1990 to 2004, will later point out, “Intelligence warnings on terrorism were rising significantly in mid-2001.” He will therefore question whether, “with terrorism and its financing already recognized as an important element of the national money laundering strategy,” this letter is “related to these warnings.” He will also point out, “negotiations between the Taliban and representatives of the United States over energy production issues in Afghanistan ended on August 2, 2001” (see August 2, 2001), and that, “Four days later, President Bush received a ‘PDB’—a presidential daily brief—with a headline warning that bin Laden was ‘determined to strike in US,’ and the body text of the PDB referred to ‘patterns of suspicious activity’” (see August 6, 2001). [Sanders Research Associates, 1/4/2006] When, in December 2003, Bergman asks the Board of Governors staff why it issued the August 2 letter, and if the letter was related to intelligence about heightened terrorist threats, he will receive no reply and subsequently be told he has “committed an egregious breach of protocol in calling the Board staff and asking the question.” [Veteran Affairs Whistleblowers Coalition, 5/14/2006] Also around this time, between June and August 2001, there is an unexplained surge in the amount of US currency in circulation (see June-August 2001). [Sanders Research Associates, 9/16/2005]