From the linked article about some of the criminal activity of the Southern Poverty Law Center (SPLC):
Among other things, the SPLC is accused of creating accounts at two banks for fake businesses that “were never incorporated, had no bona fide employees, and conducted no actual business.”
That’s hard to do. The Bank Secrecy Act of 1970, creates extensive anti-money laundering “know your customer” rules that require banks to identify new customers and be sure a business is both real and representing its activities in an honest way. You can read the regulatory requirement for a “customer identification program” yourself, and look at bank websites to see what kinds of documents you have to show a bank to open a new business account: articles of incorporation, tax forms, permits, personal identification to show who is opening the account, and so on.
Kevin Sullivan is a retired New York State Police detective who served on multijurisdictional fraud task force investigations, and is also the author of an anti-money laundering (AML) guidebook for businesses. In retirement from law enforcement, he’s the president of an AML training academy. An investigation into allegedly fake bank accounts, he told The Federalist, has to start with a basic question: “How the heck did these businesses obtain an account in the first place?”
Sullivan said, "Warning signs should have appeared at the account opening due diligence phase. Prospective banking customers that lacked appropriate verifying information, such as, never incorporated, no bona fide employees and no actual business, should never have been accepted as a customer by any financial institution."
One of a short list of things has to have happened, the Texas A&M law professor and AML scholar William Byrnes told The Federalist, if the SPLC opened bank accounts for businesses that didn’t exist: banks ignored their legal obligations and opened accounts without knowing their customers, banks had insiders who sneaked around the requirement because of a relationship with the people opening the fake accounts, or the people opening the fake accounts showed the bank forged business documents.
“If the allegation is correct,” Byrnes told The Federalist, “then it’s one of those three.”
Speaking to those possibilities, the indictment specifically alleges that the bank accounts were associated with fake documents delivered by SPLC employees: “Employee-1, and others, signed these documents containing false and misleading statements for the benefit of the SPLC.”
The documents that were allegedly used to open the accounts would be retained by the banks. Regulators routinely visit banks to check on their compliance with “know your customer” laws, Byrnes says, and to evaluate a bank’s record-keeping on customers. Whatever paperwork the bank had when they opened the SPLC’s allegedly fake business accounts would still be on hand for federal prosecutors to use in court.
Asked if the paperwork retained by the bank would identify the individual who allegedly opened the accounts on behalf of the SPLC, Byrnes didn’t hesitate: “One hundred percent. Absolutely.” If prosecutors have accurately described the activity alleged in the indictment, those individuals also face the distinct possibility of being personally indicted. “Because some human being faked the documents,” Byrnes said, and opening a bank account for a fake business using fraudulent documents is a crime, or possibly several.
The “know your customer” expectation goes deeper: A bank is expected to know its customers, but also to have some sense of the customer’s customers and business. A business account should have a history of transactions that look like the kind of transactions that the type of business would be expected to do. As an example, a business identifying itself to its bank as a single small convenience store probably shouldn’t execute a bunch of seven-figure transactions. The cash flow at a small photography studio should look like the cash flow at a small photography studio.
“Electronically, every bank has at least some minimum software that looks for these anomalies,” Byrnes said, and transactions that don’t make sense can trigger a suspicious activity report to the federal Financial Crimes Enforcement Network (FinCen) – a bureau of the Department of the Treasury. FinCen evaluates suspicious activity reports, then passes on significant reports to regulators and law enforcement agencies.
The SPLC allegedly opened bank accounts for fake businesses that didn’t do the type of work those businesses were supposed to be doing: a supposed photography studio that just made payments to informants, a rare books warehouse that just made payments to informants, and so on. Those are the kinds of anomalous transactions that tend to trigger suspicious activity reports, which can end up in front of law enforcement agencies.
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A screenshot of the indictment shows that all the accounts were opened on the same day in 2008 and, years later, closed on the same day in 2025.
We wait to see what will happen.