In her remarks at the Institute of Internal Bankers’ Annual Anti-Money Laundering Seminar on April 30, 2015, FinCEN Director Jennifer Shasky Calvery provided insight into how financial institutions’ Bank Secrecy Act reporting fits “as a critical piece in the bigger strategic picture of the global fight against terrorism”. Director Shasky Calvery emphasized that “financial institutions play a pivotal role” in gathering data that allows the U.S. government to “connect the dots between seemingly unrelated individuals and entities” in its efforts to limit the flow of terrorist groups’ fundraising and financial operations. She indicated that the reporting results in “a rich collection of high value information” that is essential to efforts to “disrupt, degrade, and ultimately defeat al-Qa’ida, ISIL and other terrorist groups.”
The Director noted FinCEN’s efforts to shape the reporting by financial institutions, “thereby shaping the data available to FinCEN”. FinCEN has used the authorities available to it to “communicate more targeted requirements and red flag indicators to industry”. This includes the use of Sections 311 and 314(a) of the USA PATRIOT Act, and the recent use of geographic targeting orders to shape the data collection efforts. Director Shasky Calvery thanked financial institutions for their work and the quality of their reporting. She described how FinCEN analyses the data it receives by looking for key terms, entities, and typologies of specific interest. The results of this preliminary analysis are combined with other data collected by law enforcement and has revealed transactions of interest and new foreign terrorist fighters and their networks.
Director Shasky Calvery made a specific request that financial institutions include IP addresses in their reporting, whenever possible. She indicated that the information is “extremely actionable” and that it is seen in only a small percentage of reporting.
The Director also emphasized that the information reported by financial institutions is not “going into a black hole, nor being stove piped in just one or a few agencies”. She noted that the information is shared broadly with domestic and international partners. FinCEN’s position as the financial intelligence unit of the United States allows it to facilitate the sharing of information internationally, which can be a challenge due to privacy and data-protection concerns. Through the Egmont Group of Financial Intelligence Units (FIUs), FinCEN is able to disseminate financial intelligence to member FIUs while at the same time protecting each jurisdiction’s interest in security and confidentiality. Director Shasky Calvery noted that “this ability to securely share information via the Egmont Group, places FinCEN and member FIUs “in a critical position to help solve the global information sharing challenges”, offering tremendous potential benefits.
Finally, the Director emphasized that the information FinCEN collects from financial institution reporting supports the follow-on action taken by FinCEN and other agencies, such as the Office of Foreign Assets Control, to counter terrorist fundraising and financial operations, including measures under section 311 of the USA PATRIOT Act.