Bad guys are innovating, so should you!

Following the tragic and deadly terrorist attacks against the United States on the morning of September 11, 2001, compliance professionals around the globe were faced with the pressing need for protocols to detect and interrupt terrorist financing cash flows. Today, we are facing a new breed of terrorism, a domestic one. I am referring to the shocking wave of massive shootings whose financing methods are different and difficult to identify and report, which can turn out to be very challenging for credit unions.

Understanding and accepting the evolution of criminals seems to be crucial, as it puts all compliance professionals in the inevitable (and necessary) place of implementing changes and innovating when it comes to approaching the ever-changing threats in money laundering and terrorist financing. 

What is FinCEN doing?

On June 12, 2019, Kenneth A. Blanco, Director of the Treasury’s Financial Crimes Enforcement Network (FinCEN), provided remarks at the New York University (NYU) Law Program on Corporate Compliance and Enforcement that highlighted FinCEN’s evolving approach to emerging threats in money laundering and terrorist financing, which includes, among others:

  • FinCEN’s procedures for processing the Suspicious Activity Reports (SARs) it receives each day through the agency’s automated business rules to identify SARs for further review;


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