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)
HOW TO SPOT A “RED FLAG” (THE BEHAVIORAL AUDIT)
Keep an eye out for these behavioral shifts in your staff:
Refusal to take leave: Afraid someone will find their “adjustments.”
Unexplained wealth: Buying luxury items that don’t match their known salary.
Working odd hours: Preferring to work alone late at night when no one is watching the system.
“Gatekeeper” behavior: Becoming overly defensive or angry when someone asks to see their records.