Part 2 of "The Importance of Suspicious Transaction Reporting in Criminal Investigations": retired RCMP officer Stephen Scott shares a detailed case study that demonstrates how a single suspicious transaction report (STR) filed by a financial institution was crucial in unraveling a complex money laundering and organized crime investigation. The discussion highlights the importance of frontline reporting, the challenges in connecting the dots, and the significant impact that STRs can have in taking down criminal enterprises and seizing their illicit assets.

Key Takeaways:

• A high-level criminal target came to the attention of law enforcement after being shot, leading to a deeper investigation into his activities and assets.
• Despite no initial STRs being filed on the target, the investigation uncovered his lavish lifestyle and suspicious financial transactions, including a $1.6 million home purchase by a 23-year-old with no apparent legitimate income.
• A single STR on an $88,000 Lamborghini purchase led to the identification of a bank account, which then allowed investigators to trace a web of financial transactions and accounts connected to the criminal enterprise.
• The case underscores the importance of frontline reporting, as even small, seemingly insignificant transactions can be the key that unlocks a much larger investigation.
• The discussion emphasizes that money laundering is not just about cash transactions, but also the acquisition of assets and the concealment of the true beneficial ownership, which can occur in small towns and communities as well as larger urban centers.

Stephen Scott

Company: S Scott (AML) and Security Consulting

Email: stephenscott@sscottamlsconsulting.com

Bio

Stephen Scott is a former member of the RCMP and in 2017 through 2021 was an investigations and training consultant to the UNODC GPML in Southern Africa. While in the RCMP, Stephen worked in the Calgary Integrated Proceeds of Crime AML Unit, INSET and the IMET JSIU where he managed and conducted money laundering, asset forfeiture, organized crime and terrorist financing investigations for 24 years. As a member of the RCMP IPOC AML Unit Stephen served as the FINTRAC liaison, CBSA currency interdiction contact and the “gatekeeper” to the Alberta Justice Civil Forfeiture program. He was a designer and facilitator on the RCMP Advanced and Basic Proceeds of Crime / ML courses as well as a facilitator at the Canadian Police College for the National Expert Witness training and Drafting Information to Obtain search warrants courses.

In 2019/20, Stephen Scott served on contract as a sworn member of the Royal Cayman Islands Police Service Bureau of Financial Investigations conducting international money laundering and asset forfeiture investigations.

Currently, Stephen is a licensed Private Investigator in Alberta and is currently contracted to firms that conduct due diligence, background, OSINT and asset recovery investigations.

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