the deposits into their P2P account, and they will likely quickly off-ramp their drug proceeds from their account DDA into cash, another account or even crypto. To that end, the AML / BSA community should proactively engage to identify this suspicious money movement.
Filing a SAR is the first stage in this process. To have a measurable impact, AML / BSA professionals should make efforts to notify the appropriate authorities of the existence of that SAR. That may likely be a state or local LE entity with only cursory familiarity with SARs, the BSA or the true meaning of the partnership in these matters. FIs can also send a tip to government websites such as FBI. gov, IRS. gov, DEA. gov or HIS. gov with the BSA ID number and the suggestion that it be further investigated. Investigations into deaths like Amy’ s will normally be initiated at a local LE level. The initial focus will be the viability of the investigation into Jack. The secondary or follow-up scheme will be further investigating the supply chain. That has the potential of taking things past the local level. This is also where the AML / BSA considerations previously had their start.
All along the investigative way, it is important to include subtle reminders of FinCEN’ s policies regarding the existence or disclosure of SARs. This is as important as the totality of the financial intelligence and information being conveyed to LE. This is because the investigative use and exploitation of P2P information and intelligence is a work in progress. Struggles with disclosure issues are foreseeable. Using the partnership between AML / BSA professionals and LE effectively is an important tool in working through those issues. Holding back information in fear of this otherwise defeats the entire purpose.
Proper use and analyzation of P2P transactional data is a“ new normal” for AML / BSA professionals. Its relevance, use or existence will now be found in nearly all criminal activities and schemes. Amy and Jack are but one example of how it has been brought to the front lines and now can be a more direct lifesaver than maybe ever envisioned. But, then again, the wisdom of following the money remains undefeated as an investigation essential.
David Tyree, CAMS, senior advisor, Financial Crimes and Money Laundering, Valid8 Financial Services, LE instructor, ACAMS, Timnath, CO, USA, d. tyree @ valid8financial. com, davidatyree @ gmail. com, Steve Gurdak, CAMS, manager, Washington Baltimore HIDTA, Northern Virginia Financial Initiative( NVFI), VA, USA, sgurdak @ wb. hidta. org
Disclaimer: The views expressed are solely those of the author and are not meant to represent the opinions of the W / B HIDTA.
1
“ ACAMS Training Webinars,” ACAMS, https:// www. acams. org / en / training / webinars
2
“ Fentanyl-Related Finance: 2024 Threat Pattern & Trend Information,” Financial Crimes Enforcement Network, April 2025, https:// www. fincen. gov / sites / default / files / shared / FinCEN-FTA-Fentanyl. pdf
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