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What is going to be the impact of the FinCEN Leak? How could they be used in our combat against Financial Crime? Does the leak indicate that financial institutions are not doing enough to deter financial crime? Does the leak give confidence that our Anti-Money Laundering (AML) controls are working?
For decades, criminal conduct has been facilitated through financial institutions because of an inability to identify the risks. However where they do, in many instances, by the time the information translates to the filing of a Suspicious Activity Reports (SAR), it can be so long "post-event" that the criminals and their network have evolved and moved on to new ways of laundering the monies.
We have also learnt through various cases that Financial Intelligent Units (FIU) struggle not only to tell the "wood from the tress" due to the sheer volume of SARs filed, but also they can be inadequately resourced both in technology and manpower to effectively use the information filed to identify illicit activities. So is there value in our current SAR filing process or do we need to innovatively rethink in our combat against financial crime at how the information is being identified, filed and used?
It is not the first time we have seen a leak in which the truth exposed was critical to assisting us fight large-scale systemic crime and corruption (Panama Papers, Paradise Papers, etc.) but there is a notable difference with the FinCEN leak - whilst we acknowledge the leak could impact and compromise investigations, and threaten the safety of institutions and individuals who file the reports, it could potentially have been needed to improve our efforts to fight money laundering.
As always our RAW Compliance events are fully interactive and an immersive experience for the audience, so come join us to discuss these issues and more, and bring your views to the table.
