CREW filed a complaint requesting that the Office of Inspector General investigate the improper removal of certain documents maintained by the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN).

Michael Cohen, President Trump’s personal lawyer, “received payments totaling more than $1 million from an American company linked to a Russian oligarch,” according to reporting by the New York Times on May 8, 2018.

Documents from the two banks involved, First Republic Bank and City National Bank, were missing from the FinCEN database. On May 16, the New Yorker reported that First Republic Bank filed a “suspicious activity report” (SAR) on the account owned by Cohen’s shell company. Previous to this filing, two additional SARs were filed regarding suspicious transactions totaling over $3 million. According to the law enforcement officer who noticed that no records of these reports were available in the FinCEN database, the fact that some of these records are missing is highly unusual and concerning.

Treasury regulations require that banks send reports of suspicious transactions, particularly those where “the bank was used to facilitate a criminal transaction” to FinCEN. While there may be an innocent explanation for why the documents are missing from the database, based on the facts that have been made public in recent days, there is reason to think that these SARs may be relevant to significant potential criminal conduct.

CREW is requesting an investigation into whether certain documents were improperly removed from the Treasury Department’s FinCEN database. There is significant public interest in understanding why the documents were removed, and potential relevance to criminal investigations.

Photo by Wally Gobetz under a Creative Commons license.

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