Missing Files Motivated the Leak of Michael Cohen’s Financial Records

Missing Files Motivated the Leak of Michael Cohen’s Financial Records

That source, a law-enforcement official, is speaking publicly for the first time, to The New Yorker, to explain the motivation: the official had grown alarmed after being unable to find two important reports on Cohen’s financial activity in a government database. The official, worried that the information was being withheld from law enforcement, released the remaining documents.

Oh boy.


The ending line is beyond chilling:

the official also added, “This is a terrifying time to be an American, to be in this situation, and to watch all of this unfold.”

Holy fuck.

Seven former government officials and other experts familiar with the Treasury Department’s fincen database expressed varying levels of concern about the missing reports. Some speculated that fincen may have restricted access to the reports due to the sensitivity of their content, which they said would be nearly unprecedented. One called the possibility “explosive.” A record-retention policy on fincen’s Web site notes that false documents or those “deemed highly sensitive” and “requiring strict limitations on access” may be transferred out of its master file. Nevertheless, a former prosecutor who spent years working with the fincen database said that she knew of no mechanism for restricting access to sars. She speculated that fincen may have taken the extraordinary step of restricting access “because of the highly sensitive nature of a potential investigation.”

I love today

This is insane.

This is honestly the most egregious political scandal in the history of our nation.

A substantial portion of this money seems to have ended up in Cohen’s personal accounts. Morgan Stanley Smith Barney filed a separate sar showing that, during that same three-month period, Cohen set up two accounts with the firm, into which he deposited three checks from his Essential Consultants account, two in the amount of two hundred and fifty thousand dollars and one in the amount of five hundred and five thousand dollars. Morgan Stanley Smith Barney marked those transactions, which added up to more than a million dollars, as possible signs of “bribery or gratuity” and “suspicious use of third-party transactors (straw-man).”

In terms of scale AND voluminous accountability, I think this is beyond anything we've seen in the modern age.

This is my current favorite video.

You are correct. An organized crime syndicate has infiltrated the RNC, and many in the GOP are either complicit or compromised. (And, btw, many in the DNC. And in governments and industries throughout the globe, but that's too indepth for us at this point in time.)

Cohen's tactics with bribes and payoffs and threats and intimidation are all exactly what one would expect from a mob fixer. trump is used to dealing with mobsters; they've propped up his business for decades, and he's laundered their money through his casinos and real estate. The destruction of government barricades to corruption, like we see here with hiding of fincen information, is the tactic of autocratic regimes (Putin helps his puppets out with tried and true methods.) Republicans, especially those in congress; of course they know. The governors all know. The intelligence community knows. All of our allies know.

I posted most of this yesterday, and I think it is imperative to understand the global crime syndicate that has taken over the WH administration, and many in elected positions in the RNC (nunes and greitens immediately spring to mind) in order to understand what Mueller's team is trying to dismantle, and why it will take years to accomplish. (FYI, I don't think trump will be in office until the 2020 election, but what do I know. I don't have a crystal ball.)


Mueller was in charge of the take-down of many of the main figures of La Cosa Nostra. He signed the paperwork allowing Sammy "the bull" Gravano to flip, and escape jail time for the 19 murders he was involved with. Gravano's testimony led to 38 members of LCN spending years, or lifetimes, in prison. (late 80's, early 90's)

Diane Sawyer interviewing Gravano. The entire interview is interesting, but watch these 30 seconds first:

I literally marvel at the sight of Manhattan when I see it, because I controlled it. I literally controlled Manhattan. When I see it at night. Those lights and everything about it, I think of donald trump and Tishman and everybody else who couldn't build a building if I didn't want them to build it...

I'm starting to think that trump cut a deal or two to inform or testify back in the day, for which he got immunity and sealed court documents that shield exposing him (like Felix Sater and Gravano). It is/was not unknown what a criminal he was, and how he did business. That is the only reason I can conceive that explains why he has not been indicted; he got immunity.

LCN was being taken apart as the USSR was failing. Lots of russian immigrant criminals moved to NY; ready to take over the LCN network. Mogilevich sent some men over to organize the syndicate. (Mogilevich, put on FBI most wanted list in 2009, removed 2015 because we do not have an extradit...

Brother's Circle. The informal name Obama administration gave to organized crime groups cooperating with other organized crime groups. Loose agreements for various syndicates to work together for additional profit. This is what we're dealing with here. Coordinated global crime syndicate. If anyone really wants to understand the scope of this investigation, this is imperative to understand. The global crime syndicate, and their involvement (for decades) with our current administration and the RNC. (Democrats are also involved, but not on the scale of the republicans.)

Here's another good article on Brothers' Circle. July 2011.

The Strategy on the whole talks in broad terms, but it does make it clear that its main concern about Russian/Eurasian gangs is the threat of the penetration and destabilization of the US economy by kleptocrat criminal-businessmen:

Russia/Eurasia: Russian and Eurasian organized crime networks represent a significant threat to eco­nomic growth and democratic institutions. Russian organized crime syndicates and criminally linked oligarchs may attempt to collude with state or state-allied actors to undermine competition in strategic markets such as gas, oil, aluminum, and precious metals. At the same time, TOC networks in the region are establishing new ties to global drug trafficking networks.Nuclear material trafficking is an especially prominent concern in the former Soviet Union. The United States will continue to cooperate with Russia and the nations of the region to combat illicit drugs and TOC.

And as for the members of the RNC who are "compromised", it is either through their knowledge of the "dark money" or shady business dealings they got involved with, or it's because decades of their correspondence were hacked and exfiltrated by the russians in 2015. This article by "The Smoking Gun" is a nice outline of what happened to SMARTTech, a server in the basement of a Tennessee bank, that held decades of information and correspondence from the RNC. Yes, I know I need better sources and need to research further. But this helps explain the absolute spineless behavior of people like Cruz and Rubio and Graham, and about a dozen other leaders that are not fulfilling their obligation to the citizens that elected them. Kompromat is the key to control.

Here's a few links on Mueller, Rosenstein and McCabe and their experience with syndicated crime. trump knows exactly who these guys are, although he has claimed otherwise; they took down his biz partners, and some have no doubt had direct contact with trump.

Mueller at the DOJ in the 90's:

In 1990, he became head of the criminal division of the US Department of Justice, where he oversaw the high-profile investigations of Panamanian leader Manuel Noriega, the Gambino crime family boss John Gotti and the Lockerbie bombing.


McCabe response to his firing:

I have been an FBI Special Agent for over 21 years. I spent half of that time investigating Russian Organized Crime as a street agent and Supervisor in New York City. I have spent the second half of my career focusing on national security issues and protecting this country from terrorism. I served in some of the most challenging, demanding investigative and leadership roles in the FBI. And I was privileged to serve as Deputy Director during a particularly tough time.


Rosenstein, 51, a Harvard-trained lawyer who lives in Bethesda, rose quickly in the Justice Department. He started in 1990 as a trial attorney with the public integrity section of the criminal division under President George H.W. Bush. He served as counsel to the deputy attorney general, an associate independent counsel and an assistant U.S. attorney under President Bill Clinton, and principal deputy assistant attorney general for the tax division under President George W. Bush.


The dude walked into a bank with his six figure checks from his bribery slush fund and just opened a bank account.

What a fucking moron!

JFC this is insane. I'm really worried they're somehow going to get away with everything.

Per Ronan Farrow on Twitter:

Experts deeply experienced with that database agreed this was extremely unusual, and said the most likely explanation was that the contents of those two reports on Cohen were so sensitive that access had been restricted.

Farrow says the treasury official who blew the whistle is now in line for up to 5 years in jail:

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

And since Trump is in office, he's likely to get prosecuted to the fullest extent of the law. That's a patriot right there.

Originally there were three SAR's filed on Cohen's LLC account.

The source saw two of them disappear from the system, ...

Those two reports detail more than three million dollars in additional transactions—triple the amount in the report released last week.

and released the third one out of fear that it too would be scrubbed. He caught a cover-up in progress.

The official, who has spent a career in law enforcement, told me, “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.” The official added, “That’s why I came forward.”

Did somebody order the SARS be removed? Or were they removed due to Muellers investigations?

This may be why Rosentstein and the SDNY conducted that raid so quickly. Sounds like there was a conspiracy to cover this up. I really doubt Mueller took the unprecedented step of removing these files from the SARs database. Who has access to this database? Mnuchin comes to mind since he's the treasury secretary. JFC. This guy is brave.

On the other hand, this seems too smart of a move by the dumbass in chief.

I think it's more a matter of too big to bail. If they were going to beat this, they would have locked shit down a long time ago, but every day more and more information is released to the public (mind you, the public becomes aware of these things today, this is hardly the whole shebang and probably not the most damaging thing found by authorities thus far) and Trump & Co. are trying to minimize damage from said information.

Think about that: this investigation is going on and they're trying to PR their way out of it, but they're trying to neutralize things only as they are released to the media. As bad as the things we know are, there's surely some way worse stuff that Trump's camp is guilty of and they have no real way of getting ahead of it.

Steve Mnuchin. It would have to come from within the Treasury department itself. That's why this is such a bombshell.

The entire US system of government is being compromised atm. It's truly frightening; this is bigger than Watergate level of cover-up.

By January of this year, First Republic had filed the three suspicious-activity reports about Cohen’s account. The most recent report—the only one made public so far—examined Cohen’s transactions from September of 2017 to January of 2018, and included activity totalling almost a million dollars. It alludes to the two previous reports that the official could not find in the fincen database. The first report that the official was unable to locate, which covered almost seven months, appears to have listed a little over a million dollars in activity. The second report that the official was unable to locate, which investigated a three-month period between June and September of 2017, found suspect transfers totalling more than two million dollars.

Here's a better description of the two missing reports. This is serious business.

Not really many options. Banks are required to monitor and report large transactions. It is also a felony to "structure" transactions to avoid detection. Dennis Hastert an old speaker of the house was busted for trying to structure hush money.


Basically when a bank notices suspicious activity, the bank files a SARS report with the treasury department. In the section responsible holding these SARS reports, there were three held for Cohen’s LLCs.

Multiple treasury department officials commented on how these are permenant records, and never before has a SARS report been removed. It’s possible they were deleted, removed, or maybe suppressed because of their sensitivity.

Two of Cohens SARS reports could not be found, which terrified the anonymous source to such a degree he risked five years in prison to alert the public.

Then his last comment how we are going through a terrifying time to be an American.

Lmao holy shit, if Smart Tech got hacked I wonder if it'll finally be publicly revealed that Republicans stole the 2004 election by using them as a man in the middle after Ohio's voting syst...

An organized crime syndicate has infiltrated the RNC,

No, not just that.

The modern RNC IS a crime syndicate at this point.

There’s been a lot of holy shit moments since Trump was elected but this is the first time I’ve read a story and really felt chilled. Like holy fuck.

I will forever respect this official.

Fucking Ronan Farrow. This dude is having one hell of a run.

Ronan Farrow has been killing it lately!

The only thing that comes to my mind is the missing sars contain transactions involving people with national security implications, like being paid directly by foreign heads of state or people related to such. (This is assuming the records are missing because Mueller is involved.)

If this was foul play, why didn't they also get rid of the third sar? Or maybe they only disappeared the other two because it wasn't just your average, every day bribery. It was... advanced bribery.

Fucking Ronan Farrow. This dude is having one hell of a run.

The implication is either

a) Someone (probably Mueller’s office or SDNY) said “keeping these under wraps is a matter of national security and security of our investigation, so we’ll keep them for now.” (most likely possibility, explosive because of what it implies about the contents of those documents).

b) Someone (probably Mnuchin or a flunky of said) removed them because they were damning to people in government (less likely, and explosive because it would go so far beyond “felony” that it is probably impossible to enforce).

It's Watergate plus treasonous collusion with a hostile foreign power. It's a capital offense against the American people and our Democracy.


Suspicious-activity reports are kept strictly confidential, as a matter of law. “sars are secret, to protect the government and to protect financial institutions,” the former prosecutor told me. “I don’t think there’s a safe harbor for somebody who discloses it.” According to fincen, disclosing a sar is a federal offense, carrying penalties including fines of up to two hundred and fifty thousand dollars and imprisonment for up to five years. The official who released the suspicious-activity reports was aware of the risks, but said fears that the missing reports might be suppressed compelled the disclosure. “We’ve accepted this as normal, and this is not normal,” the official said. “Things that stand out as abnormal, like documents being removed from a system, are of grave concern to me.” Of the potential for legal consequences, the official said, “To say that I am terrified right now would be an understatement.”

Get this article to the front.

Cohen appears to have misled First Republic repeatedly regarding the purpose of the Essential Consultants account. In paperwork filed with the bank, he said that the company would be devoted to using “his experience in real estate to consult on commercial and residential” deals. Cohen told the bank that his transactions would be modest, and based within the United States. In fact, the compliance officers wrote, “a significant portion of the target account deposits continue to originate from entities that have no apparent connection to real estate or apparent need to engage Cohen as a real estate consultant.” Likewise, “a significant portion of the deposits continues to be derived from foreign entities.” David Murray, a former Treasury official focussed on illicit finance, told me, “There are a ton of red flags here. The pattern of activity has indicators that are inherently suspicious, and the volume and source of funds do not match the account profile that was built when the account was opened.”

Cohen thought he was pretty smart apparently. No wonder the GrifterInChief is worried about the investigation into Cohen.

Edit to add: was just watching MSNBC & Avenatti was on with Ari... This breaking news was not brought up. (not that they necessarily knew about it at the time.)

fucking BOOM. again.


And I howled at the morning driving rain

But it's all right now, in fact, it's a gas

So... tl;dr - (can someone correct me if I'm wrong)?

There is an official database in which SARs (Suspicious Activity Reports) are kept. This is used for law enforcement officials to try to investigate possible crimes.

A handful of SARs (presumably those pertaining to Trump or Cohen or both) have 'disappeared' from this database.

There is (possibly) a method to prevent certain law enforcement officials from viewing certain reports (imagine certain reports are flagged sensitive).

There is a theory that (possibly) the office of the Special Counsel could have flagged this as sensitive.

Nobody has ever seen or heard of reports being hidden from individuals (see points #3 and #4)

Active theory by leaker is that someone is removing these from the database so he (or she) is attempting to leak others before they disappear.

Is the implication that there appears to be a cover up by the WH to hide this trail? Who has the ability to legally remove this data?

Jesus Christ, 3 fucking million more in payments

This guy (Farrow) is a better investigative journalist at 30 than most people in their 60's can claim to be.

And to think, he could have just lived off the family money if he had wanted to.

We're starting to see the actual evidence. I think that's why. I feel the same way. A paper trail definitely exists and it leads to a traitor in the White House.

So just taking a close look at the dates: the third one, the most recent one, covers September of 2017 to January 2018. The second one, June to September of 2017. And the first one covered seven months, but it doesn't confirm the time frame. We can reasonably assume Dec 2016 to June 2017.

Due to recent WaPo confirmation, we now know he was soliciting foreign governments like Qatar for a $1 mil fee in December 2016. There's definitely going to be foreign money involved here, it's just a question of whose?

Holy fucking shit.

That's how you know someone is a hero: when they act for the greater good in the face of personal consequences.

ST was hacked. We know this because some very bland emails leaked with the DNC emails. Benign emails to Graham and McCain and others... nothing harmful. Just enough to let them know their secrets are not secret, and they are open to the powers that be and their superior ability to "take people out" with a manufactured smear campaign. Or even worse, some actual financial or sexual impropriety, and the trump administration or the evangelicals just waiting to pounce.

(See: Franken, Schneiderman)

Cohen is fucked, and now anyone who helped conceal these transactions is too. Also, extra fucked cuz Ronan Farrow is on the case *edit to add, Ronan says the leaks last week were from just one report, the smallest of three.

I think you have an excellent point but my fear stems from how effective their "PR" aka propaganda is towards a lot of people.

Avenatti and Farrow were spotted having dinner together last week. It's likely Avenatti connected Farrow with the law enforcement official

I don't think anybody has outright said that Mnuchin deleted the records, but everyone is thinking it very loudly.

It's important to remember that while the SARS reports may have been lost, the bank still has its own records. Any good business, to protect itself, will have kept a copy of every report it has filed with relevant agencies.

I keep posting this everywhere but it's astonishing to think about to me:

It's infrastructure week.

It's really the only explanation I need for today's newsapalooza

. Some speculated that fincen may have restricted access to the reports due to the sensitivity of their content, which they said would be nearly unprecedented.

Mnuchin needs to be in front of Congress answering questions tomorrrow.

Dead on. I do AML, every FI that files SARs has to retain them for five years past the date of filing. Deleting them from FinCENs DB shows laughable ignorance.

But this whistleblower is a hero because once institutions confirmed their SAR was received by FinCEN, they typically don't reconfirm that FinCEN has it.

Edit: Added context.

Clara Jeffery:

Lots of ins and outs but two main takeaways for me:

1) At least one highly placed law enforcement official is worried that forces in government are hiding Trump's financial crimes.

2) Once one person like this leaks, it is likely that more leaks/leakers of this type will follow. Imagine what exists in the IRS.

A law-enforcement official released the documents after finding that additional suspicious transactions did not appear in a government database.


“This is a terrifying time to be an American, to be in this situation, and to watch all of this unfold.”

Yikes. This is a craaaazy story.

This may be why Rosentstein and the SDNY conducted that raid so quickly.

Seems plausible.

The next President needs to pardon this guy on his first day in office.

This is quite probably the most impactful conspiracy in centuries. The scandal side of it is only just beginning to unfold. When all the dirty laundry sees sunlight, it's going to be cataclysmic.

Does that mean the $99980 payments by Novartis may be illegal on their own? Just for the fact that they appear structured to stay below some $100000 threshold?

They won’t. There’s too much out there now. Too many State and Federal agencies.

Something to keep in mind when you hear about "The Right," and libertarian-types talk about getting rid of "regulations.'

This is the actual reason we have jury nullification. Dude is a fucking patriot.

Frank Sinatra's fucking son is going to save America, this is a weird set of events going on the past few years wtf

Why delete two other reports but keep one in FINCEN?

Incomplete or botched cover-up is the most likely answer.

SAR's should never be removed once filed. The idea is that they are not proof of a crime, they are a flag to look into something that could be a crime or could be innocent. In both cases you want the documentation for future referral.

That may be part of why a judge agreed. Destruction of evidence had already happened just not where we thought

I can’t imagine that the list of people able to actually vanish a SAR is very long at all.

I mean, prior to this I don’t think I was even sure it was possible.

If I read that right. There are still 3 million dollars in payments that we don’t know about yet.

Holy shit. Wonder what companies are shitting themselves right now.

Who knew Sinatra would have a hand in bringing down organized crime?

As a guy whose career revolves around SARs, I'd say they could go back as far as November. Banks have to file SARs every 120 days if suspicious activity continues, and when that happens, your review period starts the day after the last one ends and typically extends 90 days after that, but can go the full 120 if you feel its important to give the most up to date info to LE.

The last SAR was either a late filing (unlikely), or there was a break in the action. Sometimes stuff happens that's hard to call suspicious at the time, but then you find out more later and go back.

Those appear to be the most likely possibilities. I'm not confident that the Trump administration would be able to competently and quietly do something like remove the SARS, whereas Mueller always seems to be 10 steps ahead. If it was removed from the Trump team though, holy fucking shit.

please please please please please rope Mnuchin into this. I so badly want to see that smug fuck wearing orange jumps.

Can you explain what's going on here that makes this so significant? Genuinely interested Canadian here.

Oh shit, Farrow bomb out of nowhere.

So basically, someone in Treasury (likely a Trump appointee or ally) deleted the other two reports. It seems unlikely to me that Mueller's investigation would be responsible for this. Why delete two other reports but keep one in FINCEN?

After giving it some thought, it makes more sense the FBI was trying to conceal the nature of these reports because they contained highly sensitive information (evidence) relevant to the investigation. Perhaps they were worried Cohen would try to destroy evidence if the leaked FINCEN reports hit the media? Given how many people have access to this database, I think the fear was warranted. Regardless, all that's probably in the past for the FBI at this point...

That’s the (multi) million dollar question.

10k is automatic reporting for cash, larger non cash transactions are reviewed by automated system and bank compliance people.

If the banks filed a report, I assume they'd have to keep a record of the filing also, yes?

If they erased their copy, they'd likely be in some deep shit as well.

And even if they didn't keep the record, they'd have to still have the general banking records, yeah?

This has to be either more ham-handed cover-up, or the whistleblower (over)-reacting to something they saw that was unorthodox.

That's basically right. I think there are three theories, in order from best case to worse:

Prosecutors wanted their evidence not to become public so they requested that it be restricted. I'm skeptical of this because I'm guessing it would required a request to a Trump administration official (likely not through courts).

The Treasury took it upon themselves to shield this information from wider view. But it's not deleted, it's simply hidden from most people with access and would be turned over to DOJ if requested. I think this is the most likely scenario, personally. But I'm an optimist by nature.

There was an attempt to bury this and shield it from DOJ. I'm not a lawyer, but that would look a lot like obstruction of justice.

There goes another of Cohen's attempted defenses. Avenatti didn't steal diddly, he just found what had already leaked.

Trump has nothing to do with his business now, doncha know?  Don't you remember all those papers to end his role?

Trump has nothing to do with his business now, doncha know? Don't you remember to end his role?

Mueller, Farrow, and Avenatti all have their own styles and place.

As a side question, if there is an investigation into Cohen, does that mean it's likely that there is an investigation into Trump Org? Indicting a President may be controversial, but his business is fair game, right?

used the Essential Consultants account for personal expenses. He seems to have used it to pay his American Express, A.T. & T., and Mercedes Benz bills, marking account numbers on the memo lines of his checks. He paid initiation fees and dues to the Core Club, a social club that the Times once described as a “portal to power.” He also cut himself multiple personal checks from Essential Consultants, amounting to more than a hundred thousand dollars, on top of the million he had already deposited into his Morgan Stanley accounts.

So initiation and dues to an exclusive grown up fraternity. Wonder who sponsored him?

Scaramucci is a member.

My guess would be the director of the Treasury department, Steve Munchin.

Holy. Fucking. Shit.

Well the check was from him to himself.

He wrote it from his shell company to himself and opened a bank account with it.

The jury who hears him needs to find him not guilty.

It's possible they paid $100,000 even, and $20 was taken by the institution in fees

You know it's bad when even Wall Street banks are like "Yeah, this shit looks dirty."

Dude is super young too (~30) and has a ton of scoops under his belt and pulitzer prize winning book. Guy is a legend already. His future is bright indeed.

I would gladly chip in to a GoFundMe to help pay this individual's fines if they were every prosecuted and convicted.

I was unaware that the 5e ruleset allowed a lvl 15 Bard to recast as Bob Woodward in the middle of a constitutional crisis.

Can't wait to learn who made those payments.

My fear is that the whistle-blower will end up serving 5 years for nothing.

Those two reports detail more than three million dollars in additional transactions—triple the amount in the report released last week.

Mo dirty money!

Mo dirty money!

Mo dirty money!

Farrow probably has people lined up out his front door looking to leak a lede to him. Don’t forget, investigative journalists aren’t just public detectives, they’re amplifiers for people looking to blow a whistle. He will have a long career ahead of him, I imagine.

If the official gets caught it's likely a felony. Still, he's a hero.

Someone in the government had to get this pulled. This is a major coverup. This is what Avenatti has been talking about - why isn't anyone asking about the SARs? He says there are 3 though, not 2. Methinks he has more information on this than he has stated publicly yet.

Edit: Misunderstood the article.

That’s the million dollar question. It’s never happened before.

What kind of moron takes a check for a bribe in the first place when it’s way harder to disguise and you have to run it through the banks, these people are seriously dumb. Even the dumbest criminals would insist on cash. They probably thought they could just label everything consulting and no one would ever notice...

The White House may have used its executive power to order the destruction of evidence that it's selling American policy decisions in exchange for personal bribes from foreign countries and domestic corporations.

Did somebody order the SARS be removed?

Paging Steve Mnuchin.

I can see Franken as a smear campaign but Schneiderman seems like a legit problem that surfaced.