ABA Banking Journal - November/December 2016 - 44
>>> ANTI-MONEY LAUNDERING
How automated collaboration among financial
institutions can help banks, and law enforcement,
fight financial crime more efficiently and effectively.
BY JAMIE ROWSELL
ata! Data! Data!" he
cried impatiently. "I
can't make bricks
without clay." When
it comes to the
value of quality information to a crime
investigator, not much has changed
since Sherlock Holmes' lament in 1892.
With criminals targeting the U.S.
financial system to both clean and
move their fraudulently-obtained funds,
government expectations that financial
institutions will uncover financial crime
deeply hidden within an ocean of
legitimate customer activity are greater
Keep track of the latest in AML and BSA
strategies at the ABA/ABA Money Laundering
Enforcement Conference, Nov. 13-15 in
Washington, D.C. Register at aba.com.
ABA BANKING JOURNAL | NOVEMBER/DECEMBER 2016
These heightened regulatory
expectations require increased
diligence on the part of banks;
however, the value of the information
that banks provide to law enforcement
At the Department of the Treasury's
Law Enforcement Awards ceremony
earlier this year, Jennifer Shasky
Calvery-at the time director of
the Financial Crimes Enforcement
Network-highlighted the importance
of the relationship between banks and
law enforcement's ability to prosecute
financial criminals: "Without the
valuable information that U.S. financial
institutions provide, the significant
cases recognized here today would
likely never have seen the light of day."
While the help of financial institutions
is absolutely essential to law
enforcement, quantity can sometimes
be the enemy of quality. With a volume
of nearly two million Suspicious Activity
Reports submitted annually from all
industry types required to report, poor
quality information can greatly affect
law enforcement's ability to uncover
patterns of activity and isolate the
truly suspicious. Josh Brown, director
of security at the Fauquier Bank in
Warrenton, Va., with a background
of more than 20 years in law
enforcement, understands the negative
effect low-quality information can have.
"If a BSA officer files on something that
they know isn't suspicious, it just bogs
down the whole process," he says.
Of course, determining what is truly
suspicious is not always black and white.
With limited investigative resources
and an absence of important customer
information, financial crime investigators
can end up immobilized, creating an
inefficient decision-making process.