The Department of Justice has posted the Backpage.com indictment (https://www.justice.gov/file/1050276/download), a 93-count indictment against the seven individuals who ran Backpage.com at various times from its inception in 2004. The indictment, filed on March 28th in Federal District Court in Arizona, goes through the often disgusting and brazen history of Backpage.com. By 2010 most state AGs were pressing Backpage.com to shut down or change its ways; and by 2014 the major credit card companies and banks were blocking Backpage.com transactions. There is a good description of how they used front companies and third party payment processors to gain access to US payments. Paragraph 171 sets out the bank transactions that make up the “transactional money laundering” charges under 18 USC s. 1957(a). Page 54 lists the bank accounts and properties that are subject to forfeiture. BSA/AML staff at Bank of America, BMO Harris, National Bank of Arizona, Arizona Bank & Trust, Green Bank, Wells Fargo should review these transactions and accounts, and look at alerts, referrals, cases, and investigations, as well as account opening documentation, with a view to seeing if their processes and procedures caught what they should have. These are always good opportunities to test the effectiveness of your program against actual known bad behavior (with the caveat that this is simply an indictment containing allegations). Also, run the properties against your bank’s mortgage and customer systems to see if you have any credit-related exposure.
The DOJ Press Release (https://www.justice.gov/opa/pr/justice-department-leads-effort-seize-backpagecom-internet-s-leading-forum-prostitution-ads) gives credit to the FBI, the US Postal Inspection Service, and IRS-CI, the US Attorneys for the Central District of California and Arizona, and the Attorneys General of Texas and California. It would be great to see what role BSA reports played in the indictment of criminal activity spanning 10+ years!