Transaction Record Analysis Center (TRAC)

History

2023: U.S. government has access to database of more than 150 million American remittances

In mid-January 2023, it became known that hundreds of federal, state and local law enforcement agencies USA have access to a database of more than 150 million American remittances in more than 20 countries. The newspaper writes about this The Wall Street Journal with reference to the investigation of Senator Ron Wyden and various secret documents.

According to the publication, the database, posted in a little-known non-profit organization called the Transaction Records Analysis Center (TRAC), was created by the Arizona State Attorney's Office in 2014 as part of a settlement agreement concluded with Western Union to combat cross-border drug and human trafficking from Mexico. Since 2015, the project has expanded to allow employees of more than 600 law enforcement agencies to track the movement of funds through money services between the United States and countries around the world.

US uses secret system to track American bank transfers

TRAC data includes the full names of the sender and recipient, as well as the transaction amount. Rich Lebel, director of TRAC, said the program found hundreds of leads and uncovered hundreds of crimes involving drug cartels and other criminals seeking to launder money, as well as revealed money movement schemes that help law enforcement get a more complete picture of smuggling networks.

Internal records, including minutes of TRAC meetings and copies of 140 subpoenas from Arizona's attorney general, were obtained by the American Civil Liberties Union and reviewed by The Wall Street Journal. They show that any authorized law enforcement agency can request data without a warrant to examine people's transactions inside the U.S. for money laundering and other crimes. One of the slides prepared by the TRAC investigator shows how program data can be used to scan categories such as "Middle Eastern/Arabic names" in mass transaction records. In order to obtain materials such as bank documents or e-mail, law enforcement agencies usually must prove that the documents are relevant to the investigation and obtain them through a subpoena or warrant.

TRAC intercepts remittances made through companies such as Western Union, MoneyGram, DolEx and Euronet through its Ria brand. These services are used by millions of people, especially those who do not have bank accounts, to transfer funds between friends and relatives. It's a particularly popular way for Mexican migrants to transfer money earned in the US to family members across the border.

Euronet and Viamericas received customs subpoenas from this office, which requested data on transactions between any point in the United States and countries, including many countries in the Caribbean and Latin America, as well as, Canada,,, and, France Spain Ukraine China according to Ron Wyden. These subpoenas directed cash service companies to transfer data to TRAC.

On the TRAC database's web portal, which is in the public domain, the registration page states that TRAC is a "law enforcement-only site," and visitors are warned that their access requests will be denied unless they work in law enforcement and provide an active government email address. According to Lebel, TRAC did not identify a single case where a law enforcement officer gained improper access to data or the database was hacked by unauthorized persons. According to him, in recent years there has been an increase in the use of the program in connection with the development of the opioid crisis in the United States. Refusing to discuss funding for TRAC, Lebel only said that the nonprofit was originally created with money from the settlement of the Western Union problem, which has since been exhausted. Wyden and others said TRAC is federally funded.

Many of the subpoenas through which TRAC receives data are drawn up widely, often requiring money transfer companies to provide data on all transactions between certain locations that exceed the $500 threshold, the documents say. Even fully domestic remittances end up in the TRAC database - such as when an American living in a border state sends or receives $500 or more from another American living in another part of the country. Surveillance programs that capture fully internal records are subject to increased scrutiny by courts because of the privacy issues they raise.

Privacy advocates have long opposed mass data collection, arguing that such an approach is ineffective and contrary to constitutional and legislative expectations for privacy. Even though the appeals court ruled that the request for a large number of transaction records was overly broad, state authorities continued to send subpoenas to more than a dozen other money transfer companies. None of those companies except Western Union challenged the subpoenas in court.

After the publication of this article, Oscar Herasme, a lawyer who worked with the Arizona attorney general's office in 2008 to help create what later became TRAC, said that he was surprised to learn that this was a "metamorphosis" in the project, because it was not originally intended by any of the creators of this kind of tool.^[1]

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