COMPLIANCE
Scaled- down suspicious activity investigations
Currently , financial institutions ( FIs ) and private sector corporations are investing in scaling solutions that will expand anti-money laundering ( AML ) efforts , improve suspicious activity detection and enhance loss prevention systems . These efforts will simultaneously increase efficiency with minimal impact on operations . In the game of profitability , private sector “ wins ” naturally result in public sector investigation “ losses .” With the prevention of fraud , abuse and waste at the forefront FIs and big businesses alike , law enforcement ( LE ) must understand how to interpret and translate the scaled-down outputs for investigative purposes .
If data is information and information is power , every business , organization and government sector should now want to invest in data collection . As the use of artificial intelligence increases in AML detection and prevention programs , large-scale money laundering schemes brimming with noteworthy dollar values worthy of an investigator ’ s attention decrease . Astounding patterns of vigorous placement , layering and integration will be swapped with risk-averse , private-sector intervention . Cautionary tales of “ what could have been ” will now replace the once robust suspicious activity report ( SAR ) narratives filled with investigative leads and detrimental losses . Now that detours and road
closures speckle the investigative avenues , LE must be ready to pound the streets of collected information .
Calling all CARs
Currently , stalled-out investigations may be all LE can see on the bumpy road of monthly SAR downloads . Although the monetary value of the SAR reports may seem to have drastically diminished in the new paradigm , now is the time to test drive continuing activity reports ( CARs ). By putting the investigative gears in reverse , LE will start with the ongoing activity that followed the initial SAR filing . LE investigations will benefit by pulling out all the stops and leveraging the SAR / CAR history since the fact patterns are there .
When post-incident data is present in the CARs , LE needs to pursue the original “ owners ” of the data : the internal and external financial investigators who first took action on the alert . These genuine and verifiable sources of information ― the unsung heroes who carefully reviewed the suspicious anomalies and high-risk transactions ― hold the keys to unlocking the origins of the transactions underlying the SAR . Do not discount these stakeholders as they have analyzed these relationships and can leapfrog the LE investigation with their knowledge . They have the directions ; LE just needs to ask .
Rule-driven records
As rule detection and monitoring systems continually improve , the reality is that LE investigations will be in a constant state of pursuit . If LE invests in learning the detection rules and algorithms , they may be able to head off the proverbial chase that lies ahead . When LE learns what conduct led to the FI ’ s detection rule alerting on the customer , LE can extrapolate that information and apply it to the stalled criminal investigation . Only then can LE ask and hopefully answer the question of what occurred , what might have been the result ( aka loss ) if the activity was successful and the logic behind why the offender acted as they did . Armed with these details , LE can share the identified modus operandi with other FIs to help prevent , if not help detect , the behavior elsewhere . Crime will not stop and neither should LE . Following the leads provided by the rule detection monitoring systems offers the opportunity for further exploration of investigative avenues .
Changing gears
Knowing the road is hard , it is natural for LE to want to overlook low dollar SARs because of the anticipated minimal return on investment . When LE must make a federal case out of it , they must first meet the principles of federal prosecution which include “ recognizing both that serious violations of federal law must be prosecuted , and that prosecution entails profound consequences for the accused , crime victims , and their families whether or not a conviction ultimately results .” 1 The absence of value ( realized losses ) reduces the severity of the violation , which in turn can reduce the severity of the punishment and / or underwhelm a jury . When LE agencies triage cases on the basis of viable leads against available investigative resources , low dollar SARs seem like a defective vehicle and only worth the value of their scraps . Logically , it would seem that a savvy investigator would want to avoid this situation and look for “ deluxe ” investigations , but there is value in investing in the restoration of a SAR .
46 acamstoday . org