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Law Enforcement Highlight Priorities and Their ‘Wish List’ for Banks

Supervision News Flash
January 2021
Filing on Fraud

On December 3, 2020, the BSA Coalition hosted its fifth webinar of 2020 with more than 400 participants. Nearly 60% of attendees were bankers. Law enforcement panelists from the FBI, IRS, Northern Virginia Financial Initiative and the Ryan Group LLC provided perspectives, trends, tips and their wishes for banks.

The expert panelists agreed that COVID-19 and related government assistance programs provided new platforms for fraud. It will take years of collaboration to identify and indict fraudsters. Law enforcement had to quickly pivot from routine cases to work these government stimulus fraud cases before fraudsters made off with the proceeds. Panelists indicated that it’s helpful when a banker calls to tip them off that a significant suspicious activity report is in the pipeline as this key practice allows them to more quickly track down the fraudsters. All panelists agreed that getting to know your local law enforcement contact and picking up the phone, even if the agent doesn’t directly work in the area of the suspected crime, is the best and most successful lead for a case. While filing the suspicious activity report is required, following up with a phone call is invaluable.

Agents also highlighted the following most successful government assistance program fraud red flags:

  • Quick movement of money — more than usual from or between a business or personal account
  • Money going to disallowed program purchases, such as a car or luxury items
  • Multiple loan proceeds deposited into one account
  • Depositing loan proceeds into a personal account

Panelists also agreed that analyzing suspicious activity reports are the first piece to the puzzle. Law enforcement agencies are using advanced technology to connect information from suspicious activity reports to other data points to identify key leads. Interestingly, emoji use in such areas as a memo line is a current trend, which may indicate drug-related crimes. Institutions were asked to provide as many “tidbits” as possible in the suspicious activity report.

Law enforcement agencies’ wishes for banks included: network with your agents; talk to your customers; and say something “if the hair stands up on your neck.”

Visit for a recording of the event.