Michael Avenatti, released a memo describing payments Cohen’s firm had received, including $500,000 from a Russian oligarch and $200,000 from AT&T.
"As someone who worked at Treasury on anti-money laundering activities, my reaction to this Ronan Farrow story is 'holy st.’" —Daniel W. Drezner**
Whistleblower: two of the SARs regarding Cohen had vanished from a Treasury Department database, the Financial Crimes Enforcement Network (FINCEN), where such reports are listed.
Some payments made to Cohen were marked as “bribery or gratuity” and “suspicious use of third-party transactors (straw-man)” by banks.
"Things that stand out as abnormal, like documents being removed from a system, are of grave concern to me," the whistleblower told journalist Ronan Farrow, who first reported on the missing SARs in the New Yorker. "I have never seen something pulled off the system…That system is a safeguard for the bank. It’s a stockpile of information. When something’s not there that should be, I immediately became concerned."
Disclosing the existence of suspicious activity reports carries strict criminal and civil penalties—including up to five years in prison. The whistleblower behind the disclosures knew of the risks but felt it was important that there be public scrutiny:
The two missing SARs detailed $3 million in suspicious transactions by Cohen’s company.
"A former prosecutor who spent years working with the FINCEN database said that she knew of no mechanism for restricting access to SARs," wrote Farrow.
Just how high up does the power have to be to get documents removed from a
Treasury Dept. database?
This looks a lot like a Treasure Map and we need someone experienced to explain all the trails.