GLOBAL FINANCIAL CRIME REVIEW
Graphic 4 : Real-life example leveraging a contextual persona-based approach ( Case 2 )
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There were 1.6 billion transactions for the following :
• Low-value transactions (<$ 45 AUD [$ 29 ])
• Beneficiary in high risk CEM country ( PHL , THA )
• Transaction messages in line with CEM typologies .
Contextual monitoring then identified individuals who were making the largest volumes of transactions which met this criteria .
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Multiple low value transactions to external parties , located in the Philippines .
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Transaction messages contained phrases such as " ASSISTANCE ," " SCHOOL FEES " and " GIFT ."
Source : Quantexa
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The customer of the bank , John Smith , is a middle aged male who is divorced and is living in Western Australia .
Reporting
Having matched a customer to a potential CSAM / CSE / CST activity or network , it is crucial that law enforcement ( LE ) be notified immediately . However , performing additional checks to collect internal ( e . g ., cyber footprint ) and external ( e . g ., court records , social media or other online presence ) details should be taken to support LE for immediate intervention .
In the U . S ., the Financial Crimes Enforcement Network ( FinCEN ) provides clear guidance 9 on what should be included in a suspicious activity report ( SAR ) when reporting this activity , such as referencing keywords , indicating if human trafficking / smuggling is suspected , including IP addresses , and taking certain actions if a cyber event has occurred ( see FinCEN ’ s FAQ guidance 10 ).
A well-implemented transaction monitoring system using curated data sets and contextual persona-based models helps prevent erroneous SAR / STR filings . By accurately identifying and categorizing CSAM / CSE / CST-related activities and networks , FIs can reduce misclassifications that can lead to unnecessary resource allocation , and impede efforts to combat the actual crime and make quick arrests .
Finally , additional actions to take may include reporting this activity to various organizations . Examples include :
• INHOPE , whose focus is a world free of CSAM online , is made up of hotlines around the world that operate in all European Union member states , Russia , South Africa , North and South America , Asia , Australia and New Zealand . Activity can be reported in 48 countries . 11
• The National Center for Missing and Exploited Children at the Cyber Tip hotline at 1-800-843-5678 — the hotline partners with the Federal Bureau of Investigation , Department of Homeland Security and LE agencies .
• In Canada , the human trafficking reporting hotline is 1-833-900-1010 or for CSAM , report via the Canadian Centre for Child Protection Cybertip form . 12
The case of David Timothy Deakin , livestream child abuser
The collaborative role FIs have in detecting and reporting CSAM / CSE / CST to LE is made all the clearer in situations involving predators like David Deakin . Deakin , an American citizen , sexually exploited vulnerable children in the Philippines and livestreamed their abuse to pedophiles from the U . S ., Canada and Australia for financial gain .
124 acamstoday . org