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Jennifer ShaskyDeputy DirectorFinancial Criminal Enforcement Network (FinCEN)
FY 14-15: Agency Priority Goal
Focus Enforcement on High-Priority Threats using Pro-active Analysis
Priority Goal
Goal Overview
FinCEN is responsible for safeguarding the financial system from illicit use, which includes using enforcement measures to address high priority threats. The relevant area of responsibility constitutes tens of thousands of financial institutions in the United States and abroad. It is thus essential to take a risk-based, intelligence-driven approach to enforcement. With the technological advancements made available through the new FinCEN information technology (IT) system and a reorganization of personnel that realigns resources to intelligence and enforcement, FinCEN has an opportunity for improvement in this area. Specifically, FinCEN will leverage the new technology, FinCEN data, analytical resources, tools, and methodologies to identify high priority threats compromising our financial system. FinCEN will use this intelligence to focus its own enforcement efforts against high priority threats, and assess civil monetary penalties, impose injunctions, issue special measures under Section 311 of the USA PATRIOT Act, and apply geographic targeting orders, as appropriate. FinCEN will also use this intelligence to help focus the enforcement actions of partner law enforcement and regulatory agencies in the United States and abroad.
Key Factors:
One key external factor that significantly affects the achievement of the goal is the commitment and availability of resources of partner agencies to take enforcement action against identified high priority threats. FinCEN has sufficient legal authority to take enforcement action on its own, but not sufficient resources or jurisdiction to cover the full scope of the problem. Partner agencies must also significantly contribute to enforcement.
This APG relates to the Treasury Strategic Plan, Strategic Objective 4.1: Identify priority threats to the financial system using intelligence analysis and outreach to the financial sector
Strategies
- Develop advanced analytics algorithms related to priority threats for application to FinCEN data.
- Deliver actionable, tactical analysis on priority threats on a proactive basis to FinCEN enforcement personnel, and partner law enforcement and regulatory agencies in the United States and abroad.
- Support and maximize information sharing on priority threats by and between FinCEN, law enforcement, regulators, industry, and foreign partners.
- Coordinate action by all relevant parts of FinCEN and domestic and foreign partners against priority threats.
- Investigate high priority threats and assess civil monetary penalties, impose injunctions, issue special measures under Section 311 of the USA PATRIOT Act, and apply geographic targeting orders, as appropriate.
Progress Update
By focusing on this APG, Treasury implemented advanced analytics capabilities and improved the use and sharing of information on threats to the financial system, meeting the two-year goal to employ a proactive, intelligence-driven approach to focus enforcement efforts against high priority threats. In FY 2015, FinCEN initiated daily tactical reporting to law enforcement, foreign partners, and the intelligence community through the use of business rules in a modernized system, automatically screening Bank Secrecy Act (BSA) reports on topics of national security concern. As a result of these efforts, FinCEN quadrupled the intelligence products provided to law enforcement partners and increased the number of enforcement actions completed between FY 2014 and 2015.
Achievements:
- Initiated Global Rapid Response Program, recovering or restraining $128.9 million in funds obtained through cyber-enabled crimes targeting financial institutions and their clients before such funds could be dissipated by criminals.
- Initiated daily tactical reporting of terrorism-related financial intelligence to law enforcement, foreign partners and intelligence community.
- Issued 12 civil money penalties in FY 2015 compared to 6 in FY 2014. This penalties are against financial institutions and/or owners for willful violations of the BSA, supporting compliance and outreach messages, in particular, those focused on the casino, virtual currency, and money remitter sectors.
- The number of automated rule findings received by FinCEN’s advanced data analytics was 56,005 as of the year-end of FY 2015; in comparison, the total number of alerts generated throughout all of FY 2014 was 18,778.
- Implemented advanced analytics capabilities and improved the use and sharing of information on threats to the financial system: in FY 2015, FinCEN produced nearly quadruple the intelligence products compared to FY 2014. The results of FinCEN’s increased emphasis on the production of new products and development of actionable intelligence can be seen in the score of 96 percent of respondents to FinCEN’s annual stakeholder survey finding FinCEN’s analysis contributed to the safeguarding of the financial system, combating money laundering, and counter terrorist financing.
- Identified strategic objectives from the Strategic Objective Annual Review (SOAR) process linked to this APG as achieving Noteworthy Progress in FY 2015. FinCEN used the new BSA IT Mod system to develop advanced algorithms to identify financial intelligence targets and pursue enforcement actions to support national security priority threats. This strategic objective identifies priority threats using intelligence analysis and outreach to the financial sector.
Next Steps
Although Treasury does not plan to continue this as a FY 2016-2017 agency priority goal, due to successfully meeting our objectives, we plan to complete the following actions to sustain our progress:
- Develop a best practices document, in coordination with Ukraine project partners, to create repeatable processes to identify and recover stolen Ukrainian assets.
- Continue to focus intelligence analyses on high priority areas, including for proactive alerts and new 311 and enforcement cases.
Next Steps
No Data Available
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Performance Indicators
Number of completed enforcement actions
Number of intelligence products related to national security priorities
Contributing Programs & Other Factors
FinCEN
No Data Available
