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interest. An intelligence report
on Eagle Bank of New York was ordered. The report that came back was
alarming because it raised suspicion that the massive money deposits
were part of illegal activity. The division chief assigned the matter to
David Stone.
    I reviewed a copy of the case file that David had sent me along with a note: "Dan, take a look. I think you'll be hearing the name of this bank a
lot. Call me after your review."

    I opened the file. On the top was a FinCEN report, which looked like
dozens of others I'd seen.
    FINANCIAL CRIMES ENFORCEMENT NETWORK
VIENNA VIRGINIA 22182
    Intelligence Report
    Requester: Peter S. Yarmouth; Date of Request: April 21, 2002
Att. Special Agent Ben R. Bailey FinCEN case # 02PPPS866o
Requester Case # 02-384
    Subject: Eagle Bank of New York, et al.
    SYNOPSIS
    The Office of Investigative Support searched its financial and
commercial databases on Eagle Bank of New York. It is the subject of an investigation resulting from the bank's failure to report
suspicious activity to avert further regulatory investigation.
    The financial database listed 102 positive Currency Transaction
Reports (CTRs) on Eagle Bank of New York totaling
$211,011,009 for the month of January 2002 and 33 positive
International Transportation of Currency Monetary Instrument
Reports (CMIRs) on Eagle Bank of New York for currency
arriving at JFK Airport between January and March 2002
totaling $76,556,000. None of these reports concerned Sling &
Dewey Goods and Services, PLC. It seems that the bank had
failed to report significant suspicious activities concerning
money transfers in amounts exceeding $6o,ooo,ooo. Please see
the narrative section of this report and the enclosed database
extracts for further details.
    Prepared By: G. Walker Bryn
    Title: Lead Data Analyst

    Reviewed by: Lawrence X. Francis II
    Title: Investigative Review Specialist
    Telephone: (703) 555-5590
    Distribution: DOJ/AR/ML Date: July 28, 2002
    Any financial database information contained in this report is
sensitive and is not to be disseminated outside of your organization (with the exception of authorized U.S. government attorneys who have a legitimate legal interest in such material)
without express approval of the Financial Crimes Enforcement
Network.
    BACKGROUND
    Research on the suspects was conducted in databases available to
FinCEN. Below is a description of the databases accessed for
this report on the subjects of your request. Only positive or
inconclusive database results are included in this report. FinCEN
limits its research to only those subjects presented in your
request. Because information may exist on other entities identified pursuant to our research, you are invited to submit another
request on those subjects.
    Financial Databases: Bank Secrecy Act information received
from either U.S. Homeland Security or IRS computer centers.
    Includes Currency Transaction Reports (CTRs) filed by banks
on transactions of more than $ro,ooo in cash; reports of
International Transportation of Currency or Monetary
Instruments (CMIRs) - filed by individuals or businesses when
physically transporting or shipping/receiving more than $io,ooo
in either currency or bearer-negotiable instruments; Currency
Transactions Reports by Casinos (CTR-Cs) - similar to CTRs,
but filed by U.S. persons to report financial interest or signature
authority or other authority over accounts in foreign countries if
the aggregate value is over $ro,ooo at any time of the year, filed
annually; Suspicious Activity Report (SAR) - reports filed by
banks and other depository institutions under suspicion that one
or more of various financial crimes may have been perpetrated
by, at, or through the financial institution.

    Note: One of FinCEN's main objectives is to locate information
not normally found or used by law enforcement agents in the
field.
    NARRATIVE
    Attached referral to the U.S. Attorney's Office for the Southern
District of