In remarks at the 2015 Bank Secrecy Act Conference in Las Vegas, Nevada on June 18, the Financial Crimes Enforcement Network’s (FinCEN) associate director of enforcement, Stephanie Brooker, focused on three main points: the importance of Bank Secrecy Act (BSA) and Suspicious Activity Report (SAR) filings; FinCEN’s enforcement approach; and promoting a strong culture of compliance in the financial industry.
Referencing FinCEN Director Jennifer Shasky Calvery’s remarks last year at the same conference, Brooker reiterated the importance of SAR filings in fighting money laundering and terrorist financing (ML/TF). She said that over the last year, there has been an increase in information sharing between casinos and card clubs through the 314(b) program. “Section 314(b) of the USA PATRIOT Act provides financial institutions with the ability to share information with one another, under a safe harbor that offers protections from liability, in order to better identify and report potential money laundering or terrorist activities,” Brooker said.
The associate director of enforcement also discussed FinCEN’s enforcement actions, noting that their enforcement approach is well-reasoned, and that the assessments clearly explain the facts underlying the enforcement. “Through [our enforcement actions], the financial industry can spot trends in compliance as well as weaknesses that should help you self-identify corrective actions and industry-wide issues that may require future attention,” she said.
Finally, Brooker noted that the financial institution’s leadership—the board of directors, executive management, and owners and operators—is responsible for promoting a strong culture of compliance. “The commitment of an organization’s leaders should be clearly visible,” Brooker said. “The degree of that commitment will have a direct influence on the attitudes of others within the organization.”