ACAMS Today, Jun-Aug 2023 | Page 70

COMPLIANCE
Shifting the blame from victims to perpetrators
The FINRA Investor Education Foundation stated that almost half of the victims blame themselves for being defrauded . 4 In addition , it conducted a survey in which they assessed the perception of victims of scams . The results showed that a large percentage of respondents consider the victims to be gullible . 5 As previously explained in the first part of this article , the feelings of shame and embarrassment may be linked to the victims ’ perceptions of responsibility and the societal prejudice against them that they are partly to blame . In this regard , fraud victims feel ashamed or embarrassed and do not want anyone to know about their loss and the fact that they have fallen for a scam . As a result , reporting rates for fraud and scams are low in part due to the feelings of shame and embarrassment that prevent some victims from reporting to authorities or FIs . Fraud victims often feel as though they should have known better or done more to prevent fraud . However , it is important to stress that the blame for the crime belongs to the perpetrator , not the victim . It is also worth recalling that perpetrators are professional operators of scams and , in some instances , members of organized crime groups performing elaborate scams on an industrial scale . In addition to shifting the blame on perpetrators , it is important to consider victims of fraud as potential future victims . This is particularly the case for victims whose personal identifying information is in the possession of the perpetrator . In this case , victims of fraud are vulnerable to re-victimization .
Educating compliance professionals and customers
According to the FINRA Investor Education Foundation ’ s survey , 20 % of the victims of scams reported that a thirdparty organization such as FIs intervened or attempted to intervene in order to prevent the scam from happening . 6 In fact , half of the victims of scams who reported a third-party intervention avoided losing money . It is , therefore , important to ensure that compliance professionals receive ongoing training , especially with regard to how to detect scams and how the threat landscape evolves . The appropriate training for the first line of defense can help to prevent fraud from occurring in the first place . The vigilance and knowledge of compliance professionals or first-line employees can represent the last line of defense for clients who may otherwise become fraud victims . It is also worth mentioning that prior knowledge of fraud and scams can reduce susceptibility . As a result , it is important for FIs to educate clients and raise awareness in a proactive manner . In this regard , it is important to consider any customer as a potential victim of fraud . As mentioned in the first part of this article , fraud victims come from all socio-economic backgrounds and have all educational levels ; as a result , there is no single profile of a fraud victim .
Networking and data sharing
As previously mentioned , it is important to assist fraud victims by helping them find the appropriate organizations and agencies to support them in their recovery process . In this regard , FIs can increase opportunities for prevention by networking with organizations dedicated to tackling fraud or supporting victims . As they are on the first line , these organizations may have valuable information or resources for FIs , such as databases ( e . g ., websites , email addresses , phone numbers , etc .). FIs may integrate this data into their own fraud prevention and detection systems to proactively identify bad actors and to be aware of current trends in terms of fraud as well as to raise awareness among customers . It is also worth highlighting that there should be a shift from whether data can be shared to how FIs can share data within existing legal frameworks . In Europe , for example , Article 6 ( 1 )( f ) of the General Data

The vigilance and knowledge of compliance professionals or first-line employees can represent the last line of defense for clients who may otherwise become fraud victims

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