Speaking at an industry event today, Aaron Tapp, section chief for the Federal Bureau of Investigation’s financial crimes section, told financial crimes professionals that it “might be time to have a conversation” between regulators and law enforcement to discuss how financial institutions can best provide actionable information to law enforcement while meeting their regulatory obligations.
“The [Anti-Money Laundering Act of 2020] was maybe a start in that direction,” Tapp noted. “But I think it may be time for us to sit down and look at how can we get to the core of this problem [in a simpler way]? Technology has evolved, the types of crimes have evolved, we’re seeing all types of evolution in the crypto space—it might be time for that conversation to occur.”
From a law enforcement perspective, Tapp noted that it is useful when filing Suspicious Activity Reports for bankers to “think like an investigator,” and provide as much information as possible about the “subject, victims, venue . . . what are the actual loss amounts.” He also emphasized the importance of timely communication between financial institutions and law enforcement in cases that require a SAR filing. “The sooner the conversation can occur between the financial institution and the investigative agency, the better,” Tapp said.