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On September 20, BuzzFeed News and the International Consortium of Investigative Journalists (ICIJ) published the FinCEN Files, a comprehensive investigation of global financial institutions involving “more than 400 reporters in 88 countries”. The FinCEN Files investigation purportedly “reveal[s] how some of the world’s biggest banks have facilitated the work of notorious terrorists, drug cartels, and despots” and centers around more than 2,100 suspicious activity reports (“SARs”) submitted to the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”). Banks and other financial institutions submit SARs when they observe transactions that suggest money laundering or other illegal activity, and while these reports can support investigations and intelligence gathering, they are not by themselves evidence of a crime. The FinCen Files included SARs filed by nearly 90 financial institutions.
The FinCEN Files report leveled accusations that “Standard Chartered moved money on behalf of Al Zarooni Exchange, a Dubai-based business that was later accused of laundering cash on behalf of the Taliban. During the years that Al Zarooni was a Standard Chartered customer, Taliban militants staged violent attacks that killed civilians and soldiers.”
Standard Chartered shareholders were damaged when, based on this news, shares of Standard Chartered fell by more than 7% in intraday trading on September 21, 2020.