Written by Carolina Christofoletti and Jennifer Moreau
Pursuant to the Anti-Money Laundering Act of 2020 (AML Act), the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN)—in consultation with other relevant Treasury Department offices, the U.S. Attorney General, federal functional regulators, relevant state financial regulators, and relevant national security agencies—published the first national priorities for Anti-Money Laundering and Countering the Financing of Terrorism National Priorities on June 30, 2021. As required by the AML Act, the priorities are consistent with the National Strategy for Combating Terrorist and Other Illicit Financing.
The National Priorities report covers the following topics:
- Cybercrime, including relevant cybersecurity and virtual currency considerations
- Terrorist financing (i.e., international and domestic terrorism)
- Transnational criminal organizations
- Drug trafficking organization activity
- Human trafficking and human smuggling
- Proliferation financing
FinCEN is required to publish the AML/CFT priorities and update them at least once every four years. The AML Act also provides for FinCEN, in consultation with the federal functional regulators and state financial regulators, to promulgate regulations as appropriate to carry out the AML/CFT priorities within 180 days of the publication of the priorities.
All things cyber and crypto and domestic terrorist financing are new priorities. Domestic terrorist financing will be the hardest to implement and incorporate into an AML/CFT/CPF program. To be proactive, all financial institutions should start identifying the threats applicable to their institution and implement an action plan now.
Go through the Priorities and outline the threats that are applicable to your institution by:
1. Making sure you have the right data that corresponds to the actual state of criminal arts. For most community institutions this is a long project, so it is better to start now. You need industry codes for individuals and businesses (not just populated, but accurate) and proper data hierarchy in your core. Most important, you must guarantee that your institution is properly trained to identify and interpret those relevant data whenever they appear.
2. Reviewing customer data (industry, NRA, PEP, etc) constantly, and matching it up to the current threats.
3. Mapping and gathering the various red flags for the applicable threats and extract parameters, limits, functions, etc for your system.
4. Identifying new threats, when new criminal phenomena are to be first seen by your institution.
The underlying threats you are identifying are usually not new to your institution. But do redefine priorities if you need to do so. And, provided that criminal networks urge a good Big Data software to deal with it, always check if you are working with adequate tools.
ATII works with Strategic Partners to utilize some of those tools. You can check our Strategic Partners Section to know more about intelligence automation.
The Anti-Human Trafficking Intelligence Initiative (ATII) was founded to detect financial activity from human trafficking activities that intersect with the formal financial system at any point during the trafficking process. Human trafficking networks use a variety of mechanisms to move illicit proceeds, ranging from cash smuggling by individual victims to sophisticated cash smuggling operations through professional money laundering networks and criminal organizations. The illicit proceeds from human trafficking can include income associated with logistics, such as housing and transportation of victims, as well as earnings from the exploitation of victims. Human traffickers and smugglers have established shell companies to hide the true nature of a business.
ATII’s efforts follow the guiding principles of Environmental Social Governance, to help corporations create lasting and positive social impact. ATII’s #FollowMoneyFightSlavery movement encourages financial institutions to take advantage of our in-depth high-risk database, training resources, and partnerships, with the goal of maximizing corporate social responsibility and combating human trafficking wherever possible.