This statement is couched in vague uncertainty from the bank, and is making a claim based on the assumed riskiness of a few countries where Radvinsky does business—Ukraine, Russia, Bulgaria, and Colombia—to level an accusation it can't prove. But Wells Fargo will make note of it in the report, to cover its own reputation, just in case."Based on the inexplicable nature of the outgoing wires, for which the original sources of funding were not known, but appeared likely to be income from the customers' adult entertainment business, the information found regarding the customers' business, and the illicit nature of those businesses, which are international and may be operating in areas where underage children and other vulnerable individuals might be forced to provide services, AMLI [Anti-Money Laundering Initiative] has deemed the specified outgoing wire transfer activity suspicious."
Banks are required to file suspicious activity reports, or SARs, when they suspect something is amiss—wire transfers that aren't accounted for, money moving to and from countries where it doesn't make sense to do so, and anything that might look like money laundering. Financial institutions filed 2,503,205 SARs in 2020."That SAR is not indicative at all of sex trafficking. It sounds like they didn't have much to go on with this SAR, other than 'that country is very high risk for child sex trafficking' or something like that.”