On Thursday, April 25, 2019 the ACAMS New York Chapter hosted a learning event titled Financial Institutions and Law Enforcement: Partners in the Fight Against Financial Crime, which was sponsored by Refinitiv and Thomson Reuters.
The event featured a panel discussion with industry leaders (from left to right):
Timothy P. Murphy - President of Thomson Reuters Special Services and former FBI Deputy Director
Marcy Forman - Managing Director, Global Investigations Unit, AML Compliance, Citi, former Director of Investigations at the Department of Homeland Security
Meryl Lutsky (moderator)– Managing Director, Investigations, T&M Protection Services and former Chief, Crime Proceeds Strike Force and Anti-Money Laundering Investigations unit, New York State Office of the Attorney General and Co-chair of the ACAMS New York Chapter
Chip Poncy - Co-Founder and President, Financial Integrity Network and former Director of the Office of Strategic Policy for Terrorist Financing and Financial Crimes, United States Department of the Treasury
The primary theme of the discussion was the improvement of the public private partnership within the AML/CTF industry. The speakers shared their insights and opinions based on their wealth of experience regarding how financial institutions and law enforcement can more closely coordinate to swiftly and consistently disrupt criminal schemes.
According to the panel, some of the most challenging issues facing financial Institutions in this space include:
Burdensome Governance Processes Culture (i.e. "check the box mentality")
Technology Available/Accurate Data Information Sharing (i.e. "to connect the dots")
It was suggested that financial institutions establish outreach processes and relationships with local law enforcement contacts in order to immediately notify the government of certain SARs that may be of unique interest. The panel was mindful of the privacy requirements but noted that there should be an established escalation procedure for reporting to law enforcement.
The panel offered the following websites as a starting point for financial institutions to locate the proper law enforcement officials:
Local field offices:
The panelists urged the institutions to consider subpoenas and 314(A) requests to be valuable sources of information for internal reviews and investigations.
Several suggestions on improving coordination between institutions and law enforcement were discussed, including urging law enforcement to provide feedback more frequently and discussing the filing of SARs together by financial institutions in warranted situations.
Other best practices mentioned included improvement in data quality, more interpersonal (i.e. "in person") strategy meetings and discussions, and creating a diverse staff of ex-law enforcement and bankers to capture various points of view during the process.