The Financial Crimes Enforcement
Network works closely with
regulatory, law enforcement, private
sector, and international partners. Among
the entities with which we work especially
closely are the Federal supervisory agencies,
the Bank Secrecy Act Advisory Group, and
the Egmont Group, all described below.
Federal Regulatory Agencies
Responsibility for conducting Bank Secrecy
Act compliance examinations has been
delegated to the following Federal agencies:
•
Federal Deposit Insurance
Corporation
•
Board of Governors of the Federal
Reserve System
•
Office of the Comptroller of the
Currency (U.S. Department of the
Treasury)
•
Internal Revenue Service, Small
Business/Self-Employed Division
(U.S. Department of the Treasury)
•
Office of Thrift Supervision (U.S.
Department of the Treasury)
•
National Credit Union Administration
•
Securities and Exchange
Commission
•
Commodity Futures Trading
Commission
The Financial Crimes Enforcement Network
provides assistance and support to these
agencies to promote effective and uniform
application of the Bank Secrecy Act
regulations.
Bank Secrecy Act Advisory Group
Congress established the Bank Secrecy
Act Advisory Group in 1992 to enable
the financial services industry and law
enforcement to advise the Secretary of the
Treasury on ways to enhance the utility
of Bank Secrecy Act records and reports.
Since 1994, the Advisory Group has served
as a forum for industry, regulators, and
law enforcement to communicate about
how Suspicious Activity Reports and other
Bank Secrecy Act reports are used by law
enforcement and how record keeping and
reporting requirements can be improved.
The Director of the Financial Crimes
Enforcement Network chairs the Bank
Secrecy Act Advisory Group.
The Bank Secrecy Act Advisory Group,
which is not subject to the Federal Advisory
Committee Act, meets twice each year in
Washington, DC. In light of the expansion
of Bank Secrecy Act requirements since
the enactment of the USA PATRIOT Act of
2001, the Financial Crimes Enforcement
Network has been taking steps to ensure
that the Bank Secrecy Act Advisory Group
continues to fully and fairly reflect the
entire Bank Secrecy Act constituency. The
Advisory Group now has 50 members.
The Bank Secrecy Act Advisory Group
utilizes a variety of permanent and ad hoc
subcommittees to identify and analyze
relevant issues. Current subcommittees
focus on: Suspicious Activity Report issues;
Bank Secrecy Act examination consistency;
wire transfer reporting thresholds;
privacy/security issues; non-bank financial
institutions issues; securities/futures issues;
law enforcement issues; and reducing the
filing of Currency Transaction Reports with
little or no value to law enforcement. The
Bank Secrecy Act Advisory Group also
co-chairs publication of
The SAR Activity
Review—Trends, Tips & Issues, which
provides meaningful information to the
financial community about the preparation,
use, and value of Suspicious Activity
Reports.
Need for Government-Private Sector Partnership
"I am convinced that if we are ever going to achieve our goal of truly safeguarding the financial
system from criminal abuse under the current paradigm, the government and private sector must
act in true partnership. The word 'partnership' gets thrown around an awful lot these days, at
least in the United States, and this tends to breed a great deal of cynicism. Partnership demands
a commitment on both sides. For the private sector this means a commitment to develop and
implement reasonable, risk-based programs to address the risks of financial crime posed by each
private sector member's business lines and customer base. This program should result in the
reporting of suspicious activity and other relevant information to the government when appropriate.
The government, in turn, must educate the private sector about the risk and "most importantly
"be willing to share information with the private sector so they can develop their programs to
address the risks associated with their business and customers...
"The 20th Century paradigm of governments alone protecting their citizens from outside threats
is no longer valid in a post-September 11 world. This paradigm simply no longer applies when
enemies can melt into society and commandeer aircraft to use as missiles of devastation, or when
a group of mad men board public transportation and murder innocent souls who are simply trying
to live and work in the world. Good partners talk with one another. I am convinced that if we are
to make the present regime work, government and the private sector need to be in a constant
dialogue on these issues."
--William J. Fox, Cambridge International Symposium on Economic Crime, September 5, 2005
The Egmont Group is a global association
of 101 financial intelligence units, national
centers that have been set up to collect
information on suspicious or unusual
financial activity from the financial industry,
to analyze the data, and to make it available
to appropriate national authorities and
other financial intelligence units for use
in combating terrorist funding and other
financial crime. The Group takes its name
from the palace in Brussels where 15
financial intelligence units first met in 1995
to establish an informal group for sharing
information about money laundering.
The Financial Crimes Enforcement Network
has played a major role in helping other
countries develop their financial intelligence
units, and we help those units strengthen
anti-terrorist financing and money
laundering policies and programs. We also
sponsor new financial intelligence units for
membership in the group and provide a
secure web system through which Egmont
members can exchange information.
Our Deputy Director chairs the Egmont
Committee, which coordinates Egmont
Group activities. We also provide staff
support for Egmont's five working groups,
which are described below:
•
The Legal Working Group reviews
the candidacy of potential members
and handles all legal aspects and
matters of principle within Egmont,
including cooperation between
financial intelligence units.
•
The Outreach Working Group
seeks to create a global network
of financial intelligence units
by identifying candidates for
membership and working with
them to ensure that they meet
international standards.
•
The Training Working Group
identifies training opportunities
for financial intelligence unit
personnel. The Training Working
Group has also published a
collection of sanitized terrorist and
money laundering cases that were
used at the typology exercises of
the Financial Action Task Force,
an inter-governmental body that
develops and promotes national
and international policies to combat
money laundering and terrorist
financing.
•
The Operational Working Group
seeks to bring financial intelligence
units together on cases and
strategic projects such as insurance
schemes and stored value.
•
The IT (Information Technology)
Group examines new software
applications that might facilitate
analytical work and focuses on such
issues as data mining, information
fusion, and security.
Egmont Group Achievements
"A review of what has happened over the past decade can lead to only one conclusion . . . that
the Egmont Group has achieved [its] original goals in spectacular fashion. Right now that original
handful of units has expanded to 101 countries and jurisdictions each of which has made a
commitment to put the resources in place to accomplish what the FATF envisioned. The fact that
101 countries and jurisdictions have established units is impressive in its own right, but what is
even more important is that each FIU has made a commitment to share the information they
collect with other FIUs. We all know it works. We see it in action every day."
--William J. Fox, 13th Plenary Session of Egmont Group, June 30, 2005
