12 CONSUMER FINANCIAL PROTECTION BUREAU
In total, filers (i.e. financial institutions) submitted approximately 176,700 EFE SARs between
April 2013 and December 2017. In 2017, EFE SARs filings totaled 63,500.
Despite the high number of EFE SARs in 2017, these 63,500 SARs may account for less than 2
percent of actual incidents in 2017, according to estimated prevalence rates of elder financial
exploitation.
24
Applying one of the lowest prevalence rates, 5.2 percent, to the U.S. Census’
estimated population of 71 million adults age 60 and older in 2017 results in the estimate that
more than 3.5 million older adults were victims of elder financial exploitation that year.
25
Money services businesses have filed an
increasing share of EFE SARs
Depository institutions (DI) submitted over 70 percent of all SARs on elder financial
exploitation from 2013 through 2015. In 2016, this trend shifted significantly when money
services business (MSB) filings surpassed DI filings.
26
Filings by other entities have remained a
relatively constant share of EFE SARs since 2013.
24
Estimated prevalence rates of elder financial exploitation from studies range from as low as 3.5 percent to as high
as 15 percent, depending on the age group, time period and definition of elder abuse adopted. HHS, Nat’l Ctr. on
Elder Abuse, Admin. on Cmty. Living, What is Known about the Incidence and Prevalence of Elder Abuse in the
Community Setting?, https://ncea.acl.gov/whatwedo/research/statistics.html#prevalence
(last visited Feb. 27,
2019); Michaela Beals & Martha Deevy, The scope of the problem: An overview of fraud prevalence measurement
(Nov. 2013), available at
http://longevity.stanford.edu/2013/11/14/the-scope-of-the-problem-an-overview-of-fraud-
prevalence-measurement.
25
Ron Acierno, et al., Prevalence and Correlates of Emotional, Physical, Sexual and Financial Abuse and Potential
Neglect in the United States: The National Elder Mistreatment Study, 100 Am. J. Pub. Health 292-97 (Feb. 2010),
available at http://doi.org/10.2105/AJPH.2009.163089
(showing the prevalence rate of elder financial exploitation
by a caregiver or family member); U.S. Census Bureau, 2017 American Community Survey Table S0102 Population 60
years and over in the United States 1-Year Estimates,
https://factfinder.census.gov/bkmk/table/1.0/en/ACS/17_1YR/S0102 (last visited Feb. 27, 2019).
26
In recent years, federal law enforcement agencies have brought several civil and criminal actions against large
money services businesses for, among other things, failing to meet their anti-money laundering (AML) obligations
under the Bank Secrecy Act and, specifically, failing to implement procedures to file required SARs when victims
reported fraud on transactions over $2,000. See F.T.C., MoneyGram Agrees to Pay $125 Million to Settle Allegations
that the Company Violated the FTC’s 2009 Order and Breached a 2012 DOJ Deferred Prosecution Agreement (Nov.
8, 2018),
https://www.ftc.gov/news-events/press-releases/2018/11/moneygram-agrees-pay-125-million-settle-
allegations-company (2018 agreement between MoneyGram International, Inc. and the Federal Trade Commission);
U.S. Dep’t. of Justice, Western Union Admits Anti-Money Laundering and Consumer Fraud Violations, Forfeits
$586 Million in Settlement with Justice Department and Federal Trade Commission (Jan. 19, 2017),
https://www.justice.gov/opa/pr/western-union-admits-anti-money-laundering-and-consumer-fraud-violations-
forfeits-586-million (2017 agreement between the Western Union Company, the Department of Justice, the Federal
Trade Commission and several U.S. Attorneys’ Offices); FinCEN, FinCEN Fines Western Union Financial Services,
Inc. for Past Violations of Anti-Money Laundering Rules In Coordinated Action with DOJ and FTC (Jan. 19, 2017),
https://www.fincen.gov/news/news-releases/fincen-fines-western-union-financial-services-inc-past-violations-anti-
money (related 2017 FinCEN penalty against Western Union for AML program failures and violations of its SAR filing
obligations); U.S. Dep’t of Justice, Moneygram International Inc. Admits Anti-Money Laundering and Wire Fraud
Violations, Forfeits $100 Million in Deferred Prosecution (Nov. 9, 2012),
https://www.justice.gov/opa/pr/moneygram-international-inc-admits-anti-money-laundering-and-wire-fraud-
violations-forfeits (2012 agreement between MoneyGram International Inc. and the Department of Justice).