Bulk Surveillance of Money Transfers

Just another obscure warrantless surveillance program.

US law enforcement can access details of money transfers without a warrant through an obscure surveillance program the Arizona attorney general’s office created in 2014. A database stored at a nonprofit, the Transaction Record Analysis Center (TRAC), provides full names and amounts for larger transfers (above $500) sent between the US, Mexico and 22 other regions through services like Western Union, MoneyGram and Viamericas. The program covers data for numerous Caribbean and Latin American countries in addition to Canada, China, France, Malaysia, Spain, Thailand, Ukraine and the US Virgin Islands. Some domestic transfers also enter the data set.


You need to be a member of law enforcement with an active government email account to use the database, which is available through a publicly visible web portal. Leber told The Journal that there haven’t been any known breaches or instances of law enforcement misuse. However, Wyden noted that the surveillance program included more states and countries than previously mentioned in briefings. There have also been subpoenas for bulk money transfer data from Homeland Security Investigations (which withdrew its request after Wyden’s inquiry), the DEA and the FBI.

How is it that Arizona can be in charge of this?

Wall Street Journal podcast—with transcript—on the program. I think the original reporting was from last March, but I missed it back then.

Posted on January 24, 2023 at 7:14 AM27 Comments


Duchess Gloriana XII of Grand Fenwick January 24, 2023 8:15 AM

Technologists often loose sight of the simple non-technological solutions to problems. Here in Grand Fenwick my clever subjects solved the problem of financial privacy long ago; Gold for savings and cash or silver for everyday transactions.

Winter January 24, 2023 8:28 AM

Leber told The Journal that there haven’t been any known breaches or instances of law enforcement misuse.

Does that mean they never looked for breaches or misuse? Or have they simply defined breaches and misuse such that they do not occur?

Or, have criminals become so incompetent that they were never able to bribe any LEO? In Arizona?

Rob K January 24, 2023 10:56 AM

It’s probably run out of Arizona because someone in Arizona “had an itch they wanted to scratch” (probably to do with cross border drug running), they built it, and it was a useful tool they could share with others (much like good open source software).

No one has any effective power to stop them. Only the government has any power; no one outside of it has any actual power over the government.

Matt January 24, 2023 11:02 AM

“Leber told The Journal that there haven’t been any known breaches or instances of law enforcement misuse.”

Warrantless law enforcement use IS misuse.

Winter January 24, 2023 11:31 AM


4th AMENDMENT is a dead law.

When Snowden’s revelations made the headlines, Americans were shocked that all the abuse of privacy by the USA that was heaped upon non-Americans had come home to abuse Americans too.

Now again, Americans find out their privacy is as insecure from USA government as is the privacy of non-Americans.

I do not expect Americans ever to learn that if your government abuses human rights elsewhere, they eventually, or very soon, will abuse human rights at home.

So, just look at what your government is doing to foreigners. You then know what they are doing to your compatriots and you.

Clive Robinson January 24, 2023 11:55 AM

@ Bruce, ALL,

The value of $500 is to low for criminals to want to use.

Thus I suspect the real intended purpose is to catch immigrants and similar “sending money home” and so build up “maps” to “assist” targeting future anti-immigrant activities.

The trick being the more information you can build up before you take action the more effective the action appears once you start it. It’s only a few months after the initial round ups those surviving start disapearing by using other methods to get money home.

But the result is such a system will fairly quickly being a failure just like CCTV, because the targets have agency and thus can evolve defences. So it will “move the problem” rather than “solve the problem” the State Legislature think they have. But then if that moves them out of their State…

You might remember about a decade and a half ago the author Larry Niven as an advisor to the US Gov was asked for suggestions on how to reduce “health care” spending. His reply was to spread faux information in spanish to the latino population of illegal organ harvesting in ERs[1]. In essence convince them that going to a Dr the first blood test would have them “tissue typed” then if a high ranking person needed an organ transplant the latino would get used as the donor. Thus the latino population would reduce it’s health care usage, and hospital health care costs would come down commensurably.

The basic mentality behind these systems is the same, which is not “solve the problem” but “move the problem” so it becomes “Somebody Elses Problem”(SEP) thus effectively hidden from view[2] where you or your voters/funders are.

[1] https://gizmodo.com/larry-niven-tells-dhs-to-spread-organ-harvesting-rumors-370762

[2] The author Douglas Adams wrote a book where he described a “Somebody Elses Problem”(SEP) field to hide things rather than make them invisable. The idea is whilst the object was still there the brains of people seeing it would ignore it as it was obviously somebody elses problem ro deal with, and they would simoly move around it whilst effectively looking in another direction.

JonKnowsNothing January 24, 2023 12:14 PM

@Winter, All

re: I do not expect Americans ever to learn that if your government abuses human rights elsewhere, they eventually, or very soon, will abuse human rights at home.

When on occasion, the topic is broached, in violation of the proper etiquette being “do not talk about religion or politics”, I simply ask them this:

  • What country will you be deported to?
  • Do you have your bags packed?

When there is a splutter of indignation, I point out, that the law is just a piece of paper. Such things change very easily. History is replete with examples of expulsions, and redefinition of “who belongs here”.

Then I tell them that if we are in the same camp, and I’m working the cook line, I promise to “ladle from the bottom” for them.

Winter January 24, 2023 12:14 PM


Thus I suspect the real intended purpose is to catch immigrants and similar “sending money home” and so build up “maps” to “assist” targeting future anti-immigrant activities.

That sounds more than plausible.

lurker January 24, 2023 2:35 PM

Use Google search on “Transaction Record Analysis Center” and top of the results is their Single Sign-on Portal, just a logo and a login window. Maybe that’s a result of the recent publicity, but TRAC itself has no other presence in the first couple of SERPs. Oblique references from other places indicate its major purpose is to detect money laundering and human trafficking, and to educate LEAs on detection and prevention of those activities. That’s gotta be a Good Thing, no? Please withold essays on perversion of motives, or Constitutional relevance.

The system looks like it might be run by Forcepoint who have a whitewashing page at


Note also the existence of a “Transactional Records Access Clearinghouse” (TRAC) at Syracuse University, which performs a vaguely similar monitoring on the Federal Govt.

Paul Rain January 24, 2023 3:58 PM

Very simple to understand why Arizona runs this. The Arizona AG filed a nuisance suit against Western Union, and the settlement agreement allowed them to extort information from Western Union- and threaten other money transfer services with similar suits.

Ted January 24, 2023 6:17 PM

@Paul Rain

Yes, that’s how I was starting to understand it also.

What I found equally intriguing was how the HSI Phoenix office came to use its customs authority to direct Western Union to submit records to TRAC after WU’s settlement with the Arizona AG expired in 2019.

Sen. Ron Wyden laid out the reasons this was problematic in his March 2022 letter to the DHS IG.

It looks like Sen. Wyden just sent a letter to the DOJ’s IG on Jan 18, 2023.

The Wall Street Journal article says that “Money-services companies are more loosely regulated than banks, often at the state level.” At this point I’m a little unclear how money service businesses are regulated.

SpaceLifeForm January 24, 2023 6:18 PM

Paypal again


Clive Robinson January 24, 2023 8:29 PM

@ lurker, ALL

Re : Technology is agnostic to use.

You list a bunch of privacy invading agents, and unlawful actions, then ask,

That’s gotta be a Good Thing, no?

As I’ve explained numerous times in the past on this blog, technology usage is under the control of a “Directing Mind” that has “agency”.

As an “observer” you have actually know knowledge of the Directing Minds “intent”. All you have are,

1, Your observations of their behaviour.
2, What ever they are prepared to say.

Neither are actually of any use generally of determining what the Directing Minds “Intent” is.

However you as an observer decide “good or bad” based on those two highly unreliable sources of information.

Thus your chances of saying accurately “good or bad” is shall we say “worse than you would get flipping a coin”. Because of the “think of the children” arguments used so deceitfully and so frequently in the past, my suspicion is that the true intent is being kept hidden. But even if it’s intent realy is “good” today, what of tommorow, once the data is collected it can be used for any purpose anyone with access choses without constraint or oversite, and you as an observer will have nothing to observe untill long long long after any harms have happened.

Look on that “data” as a ship load of Ammonium Nitrate that has been confiscated, for apparently “good” reasons. Where do you store it and how do you ensure it does no harm? Get it wrong and city gets blown up and three months of an impoverished Nations food supply gets destroyed, and many people get killed, injured, or have their lives shortend. Now was that Good or Bad?

The same applies to that data, and the potential it has for “harm” is many many times greater than it’s potential for “good”.

You might not agree, but then by definition you and I being different people can not have the same view point, as view points are personal to the observer and where they stand.

So my viewpoint based on my experience is that this is a very very very bad idea. Especially as I can easily think up more “harms” than “benifits” for society on the data being collected. Especially as the collection of this data has many hallmarks of being “Politically Motivated”.

name.withheld.for.obvious.reasons January 25, 2023 3:10 AM

My experience has lead me to conclude that payment brokers, those processing payments for banks as third parties, which for example the California DMV does, are shielded from government restrictions on collecting such information. But, what the government then does is act as a third party to the third party and purchases the data back from the payment brokers. Guess who pays for the transaction, the user, twice. Once in the fee to the broker, and the repurchase of the data back from the broker. If this system isn’t just completely corrupt, tell me how it isn’t.

It is not unlike the federal tax processing system that is used in the United States. A total giveaway to third parties.

And may I suggest it is even worse than you think, some payment brokers are notorious private intelligence firms doing both the dirty work and what others would call respectful commerce–not true my friend, good buddy, old pal.

PaulBart January 25, 2023 9:06 AM

Thus I suspect the real intended purpose is to catch immigrants and similar “sending money home” and so build up “maps” to “assist” targeting future anti-immigrant activities.

I would love this to be true. But it is delusional to think either party wants to halt immigration. Good try. Next theory.

Winter January 25, 2023 11:36 AM


I would love this to be true.

If you are an American, I guess all your ancestors were immigrants or the descendants of immigrants. So this hope is rather hypocritical. But we know that immigrants are opposed to newer immigrants everywhere.

But it is delusional to think either party wants to halt immigration.

Why should they? Given that 99% of Americans are the descendants of immigrants, and immigrants are the only reason the US population is not shrinking like the European, Russian, or Chinese populations.

Stopping immigrants is a very stupid policy as the Brits have found out.

Retief January 25, 2023 12:04 PM

@winter @paulbart

Not to mention that the US like many other countries is slowly suffering from demographic collapse; immigration is the most effective way real-world way to prop up the system as it goes upside down.

The conservative movement is trying to outlaw abortion and contraceptives purely on specious religious principles.

Winter January 25, 2023 12:30 PM


The conservative movement is trying to outlaw abortion and contraceptives purely on specious religious principles.

That is because immigrants tend to not vote conservative. Also, immigrants tend to be not Caucasian (and half the people in the Caucasus are Muslims anyway).

Conservatives hope that the forced labor babies will be white and vote conservative. Both assumptions are likely wishful thinking.

Clive Robinson January 25, 2023 2:11 PM

@ PaulBart, Winter,

“But it is delusional to think either party wants to halt immigration.”

Some of them want a “certain type of immigrant” look at the current “hate on” Chinese second and third generation that have done well for themselves.

What certain people want is slaves / serfs / life long endentured who will work hard at drudge work to make their “sponsors rich”.

Imigrants prospering and sending money home is signs that they are not doing what they are supposed to do. To some “self entitled” people they take the view that that money is in effect being stolen from their rightfull ownership.

We see this mentality in the UK and it’s rife in the “blue rinse brigade” who read the Daily Mail and The Telegraph. Some of whom you might remember brought their views to the US and got their social media accounts suspended and ended up on far right web sites, being lauded for their attitudes. One was so set in her ways she liabled an individual, would not appoligise, got taken to court, lost, got made to sell her home and most of everything else to pay her legal bills and unable to get work as a biggoted comments journalist any longer so went to the US to support certain people…


She is mild compared to others we still have to put up with here even though we do not have a “right of free speech” the self opinionated behave as though we do…

vas pup January 27, 2023 5:50 PM

Current condition is ‘1984’ on double steroids.
The most troubling is zero judicial oversight. Just like Stasi, NKVD-KGD, you name it.

maksromanov November 5, 2023 4:39 PM

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