TPM Reader TH thinks he knows where Michael Avenatti got his amazingly specific details. And it sounds right to me …

I work as an Anti-Money Laundering and Bank Secrecy Act Specialist at a financial institution. Every bank/credit union/etc will have someone who’s responsibility it is to examine transactions and file Suspicious Activity Reports (SARs) with FinCEN, a department of the Treasury. This is what I do.

“They’ve also confirmed the dollar amounts. So while we still don’t know where or how Avenatti got this information he must have had access to one of Cohen’s ledgers, a bank statement or perhaps an investigative document. The details are simply too specific.”

Upon reading Avenatti’s document, it’s obvious that he has his hands on (multiple, I think) SARs that have been filed on Cohen. They are structured almost exactly as we write them. The KYC information at the beginning is a huge tipoff. This is something every bank is required to compile when a business account is opened, and it’s what AML staff would refer back to it when examining transactions to see if the account is “behaving” differently than expected. This KYC information would never be included in a bank statement or a ledger. It would only come from a financial institution, and is what is included in SARs narratives to justify their filing. Furthermore, there’s info in the document from multiple banks. Unless Avenatti has people at multiple different banks leaking him info on Cohen (he doesn’t) it comes from a SARs.

We know from the WSJ that at least one bank has filed a SARs on Cohen:

https://www.wsj.com/articles/trump-lawyers-payment-to-porn-star-was-reported-as-suspicious-by-bank-1520273701

I’m pretty gobsmacked that someone would leak SARs to Michael Avenatti, but we live in crazy times. I’ve been trying to think who all would have access, and it’s basically: FinCEN staff, law enforcement who request them, regulators, the bank staff who filed them originally, and possibly independent auditors who come in to make sure banks are filing BSA paperwork properly. My guess would be it’s someone at FinCEN doing it, but I wouldn’t bet a massive amount of money on it.

I would, however, bet massive amounts of money that Avenatti somehow has his hands on SARs filed on Cohen.