Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued updated guidance to clarify how financial institutions can share information with each other about suspected fraud under section 314(b) of the USA PATRIOT Act.
Treasury Press Release
Fact Sheet
Financial Institutions can register here to share information about fraud under section 314(b)
IT & DATA SECURITY (MITIGATING THE “INSIDER THREAT”)
As seen in the TD Bank case, an employee with too much “access” can sell your customer data to syndicates.
- Principle of Least Privilege (PoLP): Employees should only have access to the specific folders and databases required for their current task.
- Access Revocation: Have a “Termination Checklist” that ensures all digital access (Email, VPN, Banking) is revoked within 60 minutes of an employee resigning or being dismissed.
- System Logs & Audit Trails: Enable “Read/Write Logging” on your server. If a customer’s data is leaked, you need to know exactly which login accessed that record and at what time.
- Encryption at Rest: Ensure that sensitive files (like your customer ID numbers or payroll spreadsheets) are encrypted so that if a staff member copies them to a USB, they cannot be read.