NAFCU recommends more, better info sharing in FinCEN program
To better combat money laundering and terrorist financing, NAFCU's Kaley Schafer offered recommendations to strengthen the information shared between government agencies, law enforcement and financial institutions through the Financial Crimes Enforcement Network's (FinCEN) 314(a) program.
In a letter to FinCEN, Schafer, NAFCU's regulatory affairs counsel, acknowledged the benefits of the program but said credit unions often don't receive enough information from law enforcement to effectively identify a potential threat.
"FinCEN's regulations state that each law enforcement agency seeking information through the 314(a) program should include 'enough specific identifiers, such as date of birth, address, and social security number that would permit a financial institution to differentiate between common or similar names,'" Schafer wrote.
However, when only a common name is provided, it can be difficult for credit unions to sort through member records and increases the risk of a false positive. Schafer recommended that FinCEN require certain information, such as a known telephone number, and information required for customer identification programs (CIP) when submitting a 314(a) request.
Schafer also flagged for FinCEN difficulties law enforcement face related to documenting the seriousness of the underlying criminal activity when placing a suspect on the 314(a) list and requested that the agency ensure the efficiency of the program.
On the 314(b) information sharing program, Schafer asked that FinCEN enhance it "by expanding the scope to allow financial institutions to share information about fraud."
"Sharing information regarding fraud is currently limited to situations where the fraud is part of a money laundering scheme or terrorist financing," Schafer said. "… Fraudsters often conduct fraudulent activities at multiple institutions before an institution recognizes irregularities and raises suspicions. An expanded scope would lead to lower losses suffered and increase the chances of identifying suspects. Additionally, a more robust information sharing program would likely increase voluntary utilization by credit unions."
Read Schafer's full letter here.
Fraud , BSA
Add to Calendar 2020-06-09 14:00:00 2020-06-09 14:00:00 The New BSA/AML Examination Manual FFIEC updated the BSA examination manual for the first time since 2014. Is your organization ready for an emphasized risk-based approach to BSA/AML supervision? During this webinar, we’ll examine the updates to the manual and take a look at what your organization can do to prepare for their 2020 BSA/AML exam. Key Takeaways Highlight the changes to the examination manual Expectations of the regulators Best practices to prepare for an examination Common exam findings, and how to avoid them Register Now For On-Demand AccessRegistration is complimentary, but you must register to attend. One registration gives your entire credit union access to the on-demand recording until June 9, 2021.Already registered? Go to the Online Training Center to view live. Who Should Attend? NAFCU Certified Bank Secrecy Officers (NCBSO) NAFCU Certified Compliance Officers (NCCOs) NAFCU Certified Risk Managers (NCRMs) BSA staff Risk staff Compliance staff Audit staff Credit union staff attorneys, legal staff Education Credits NCBSOs will receive 1.5 CEUs for participating in this webinar. NCCOs will receive 1.5 CEUs for participating in this webinar. NCRMs will receive 1.5 CEUs for participating in this webinar. CPA credit information is below; recommended 1.5 CPE credits. CPA Certification Credit Information Reviewer: Josie Collins, Associate Director of Education, NAFCU Learning Objectives: Highlight the changes to the examination manual. Expectations of the regulators. Best practices to prepare for an examination. Common exam findings, and how to avoid them. Program Level: Basic Prerequisites Needed: None Advance Preparation Needed: None Delivery Method: Group Internet-Based Recommended CPE Credits: 1.5 credits Recommended Field of Study: Regulatory Ethics - Technical National Association of Federal Credit Unions (NAFCU) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. Learn more. About Our Webinars Our webinars are streamed live from NAFCU headquarters near Washington, D.C. Your audio/video feed of the presenters includes presentation slides and downloadable handouts. You can easily submit your questions to the presenters at any time during the live broadcast, with no dialing over the phone! The audio and video stream directly through your computer. Web NAFCU firstname.lastname@example.org America/New_York public
NCCO, NCRM, NCBSO, CPE
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