FinCEN Files: Q&A with ICIJ's Emilia Diaz-Struck

Conversations with Data: #59

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Managing a data-led investigation is no small feat no matter the size of your organisation. But how do you build a collaborative culture with hundreds of journalists across the world and ensure your investigation makes an impact?

In this week's Conversations with Data podcast, we talk to Emilia Diaz-Struck from the International Consortium of Investigative Journalists' (ICIJ) about its latest cross-border investigation, the FinCEN Files. As ICIJ's research editor and Latin American coordinator, she explains how the team used data-driven tools to sift through and analyse trillions of dollars in transactions to reveal the role of global banks in industrial-scale money laundering.

You can listen to our entire podcast on Spotify, SoundCloud or Apple Podcasts. Alternatively, read the edited Q&A with Emilia Diaz-Struck below.

What we asked

Tell us about your role at ICIJ.

I am currently based in Washington, D.C. and I oversee all of our data and research work. I work with an amazing team of data journalists, researchers and developers. We mine up to millions of records for our investigative projects and analyse complex data sets. At the same time, we collaborate with journalists all around the world. I also coordinate our Latin American partnerships and focus on bringing great journalists on board to work on large investigations with us.

In September 2020, ICIJ published the FinCEN Files. Talk to us about this investigation.

The FinCEN Files is an investigation that started after Buzzfeed reached out to us. They had a collection of documents called suspicious activity reports (SARs) that haven't been known to the public. These reports are filed by banks to the Financial Crimes Enforcement Network, known as FinCEN, a financial crime agency within the U.S. Department of Treasury -- hence the name of the project. They report on transactions that could be flagged or considered suspicious because they could potentially involve money laundering.

The files were obtained as part of the U.S. congressional investigation into the Russian interference of the 2016 U.S. elections. The FinCEN Files investigation looked at 2,100 suspicious activity reports. Among those reports, 98 percent were filed between 2011 and 2017. To put that into perspective, that's only 0.02 percent of the reports that FinCEN receives in a single year. So the findings are only a small sample of the activity during that period.

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ICIJ and 108 media partners spent months investigating secret bank reports shared by BuzzFeed News.

What did these suspicious activity reports reveal?

The 2,100 reports gave us an unprecedented look into the anti-money laundering monitoring system by banks. It also allowed us to explore some of this monitoring system's failures. For instance, ICIJ found a lag of 160 days since the activity started until banks reported it to the authorities. However, the law says they usually should report it in the first 30 days. The investigation also revealed some reporting system failures. In about half of the reports, they had at least one client they flagged where they didn't know who the person or company was behind the transaction. These reports came from intermediary banks, which are used to pass money through the financial system from bank to bank. Due to U.S. law, these types of corresponding or intermediary banks are the ones that are sending out these reports to FinCEN.

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Emilia Díaz-Struck is ICIJ's research editor and Latin American coordinator. She has taken part in cross-border investigations such as ICIJ's Offshore Leaks, Luxembourg Leaks and Swiss Leaks projects; a collaboration between journalists from 5 countries that revealed the illicit trade of coltan; and a collaboration with Costa Rica's La Nación newspaper on a real estate scandal involving a former Venezuelan magistrate who fled ahead of an arrest warrant.

Who took part in the FinCEN Files investigation?

The investigation involved more than 400 journalists in 88 countries and took place over 16 months. Altogether, we were 110 media outlets participating in the project.

How did you start to collaborate with these global partners?

We always start by figuring out what kind of data we have in front of us. Are there any interesting people or organisations of public interest in the data that allow us to bring partners on board? We also ask ourselves, how global is this data? One of the findings was that the data connected to more than 170 countries. So that's when you start figuring out highlights tied to specific countries. So if we noticed Venezuala in the data, we would start involving partners in Venezuela. We continued developing partnerships with other countries based on relevant data showing up in the files.

About 16 months ago, we began planning and held a big meeting in Germany. The aim was to figure out what the documents were about, but also to coordinate. For instance, how are we going to work together? Are there any potential collaborations across countries? Partners also agreed on keeping it confidential and to share with everyone and not to keep the findings for themselves.

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Explore Confidential Clients. It shows the notorious names behind billions in suspect money. The categories reflect allegations that often prompted the reports or suspicious activity flagged by banks and are not necessarily indicative of misconduct.

What kind of data-driven tools did you use for the investigation?

Our tech team has developed a number of useful tools for us. One is called the DataShare. This open-source tool allows people to explore the documents. All the documents for the FinCEN Files investigation were added there. So that helps people explore the data in a secure way. DataShare also does entity extraction. So you can get a sneak peek of what entity names are there and do searches, as you would do in an open search platform. But this one was protected and only exclusive for the project.

We also used what we call the Global I-Hub. This collaboration platform is like a secure social network for journalists, where you have groups and subgroups allowing you to organise the whole investigation along with a project manager to provide guidance. The complexity of the files meant we had to do a large collaboration. Data-wise, this project involved more than 85 journalists in 30 countries extracting data from the files. While we tried to automate as much as possible, a lot of manual work was required to extract the data from the files. We couldn't get all the insights we needed. So we actually created what we call the 'data extraction party' done via the Global I-Hub.

Finally, what has been the impact of this investigation?

It is still too soon to say. But so far there have been discussions about regulations. For instance, Elizabeth Warren and Bernie Sanders have made public statements about the FinCEN Files and they're looking into the regulatory part of it. We know in Europe there have also been open discussions examining the current regulation that banks have, which is tied to this reporting system. There are questions about whether there are improvements that can be made into the regulatory system regarding the different aspects that our investigation highlighted. There are many stories with this investigation and there are still more to come.

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Our next conversation

In the next episode of our Conversations with Data podcast, we will speak with Micah Cohen, the managing editor at FiveThirtyEight. He will talk to us about the uncertainty in polling data and how journalists can report on the upcoming US elections.

As always, don’t forget to let us know what you’d like us to feature in our future editions. You can also read all of our past editions here.


Tara from the EJC Data team,

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