In a news release issued yesterday, FinCEN has launched the “FinCEN Exchange” program to enhance information sharing between financial institutions and law enforcement.
Per the release,
“FinCEN, in close coordination with law enforcement, will convene regular briefings with financial institutions to exchange information on priority illicit finance threats, including targeted information and broader typologies.” Through these regular and as-needed operational briefings, both law enforcement and financial institutions will benefit, as law enforcement will be able to obtain “information intended to support specific lines of investigation or broader typologies related to a particular illicit finance threat…[and] financial institutions will be better equipped to incorporate responsive information into SARs.”
Information shared through previously held briefings has resulted in private sector SARs and public sector cases on: “weapons proliferators, sophisticated global money laundering operations, human trafficking and smuggling rings, corruption and trade-based money laundering networks, among other illicit actors.”
This is exciting news for those working in financial institutions, as sometimes it can be frustrating to work on a case or file a SAR and not know if its useful for law enforcement. It appears that the FinCEN Exchange briefings will allow financial institutions to more specifically target areas of priority and better identify risks. Participants in the FinCEN Exchange will be able to obtain information both from law enforcement, other governmental organizations, and other participating financial institutions.
FinCEN indicated that private-sector participation in FinCEN Exchange is voluntary and there are no new regulatory requirements. Existing information-sharing mechanisms through the USA PATRIOT Act (such as 314(a) for law enforcement and 314(b) for financial institutions) remain in place. The purpose of the FinCEN Exchange is to have better focus on high-value and high-impact activities and strengthen the overall anti-money laundering framework for participants.