Remittance Beneficiary B. BUSA filed a SAR on Beneficiary B on September 4, 2007, as part of the remittances identified by BSA and operations personnel as potential illegal activity. The SAR covered 27 transactions he received from April to July 2007 totaling $92,900 from the United States and Ecuador. The same suspicious activity continued through August 2008. In the year following the SAR, Beneficiary B’s transactions appeared on BUSA’s monthly monitoring reports four more times. In total, Beneficiary B received 28 transactions totaling more than $102,000 in the year after BUSA filed a SAR on him. Just as with Beneficiary A, BUSA failed to take any further steps to investigate and report the continuation of activity it had previously reported as suspicious in September 2007.
