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Creating partnerships to combat pandemic crime and beyond
By creating agile partnerships between law enforcement, FIs, FIUs, nongovern- mental organizations (NGOs) and affected agencies at all levels of government, greater strides will be made in combating financial crimes during the pandemic and beyond. Police officers do not have to think on national or even state/provincial levels to create these partnerships. Local partnerships that focus on unique and prevalent COVID-19- based fraud in community areas and counties will afford opportunities for participating entities to leverage partner capabilities and heavy lifting abilities. In the United Kingdom (U.K.), there are established community safety partner- ships within every municipal jurisdiction that tackle safety and crime issues.11 What is unique about these partnerships is that the police are but one sitting member of a much larger group that collectively plans crime and harm reduction. The intent of these groups was to recognize that the police are not the sole problem solvers of crime but one cog in a larger wheel of agencies and community groups. In these groups, comprehensive decision-making processes occur in a more informed and enlightened manner where all corners of a community are contributing. Using COVID-19 fraud as a driver, these groups, or ad hoc groups assembled for specific problems, can leverage local expertise and resources to keep their constituents informed and protected. For these groups to be successful, the approach must be robust, energetic, as well as driven by shared goals and urgency.
On national levels, there are opportunities to forge focused partnerships through entities such as police organizations, the International Association of Chiefs of Police being one,12 or bankers associa- tions, which can draw typological and red flag indicator data that can inform law enforcement efforts and other stake- holders collectively. In most jurisdictions, legislation exists that allows law enforcement to inform communities of
crime risk. Using this legislation, law enforcement can generate targeted releases of infor- mation to specific industries outlining typologies and crime indicators as well as bad actor lists derived from COVID-19 fraud investigations.
One such example of targeted information sharing is done through the U.K. National Crime Agency (NCA).13 Within this framework, the U.K. established the Joint Money Laundering Intelligence Taskforce (JMLIT). This group consists of 40 FIs, the Financial Conduct Authority, Cifas and five law enforcement agencies: the NCA, HM Revenue and Customs, the Serious Fraud Office, the City of London Police and the Metropolitan Police Service. In these huddles, law enforcement (through legally sanctioned channels), provides enhanced intelligence to FIs with the expectation that they will in turn investigate illegal activity and report their findings to national regulators.
As the realities of the pandemic continue to roll over the world, it is very evident that this will have a generational effect on many aspects of society. The economic outlook, public sector funding, private sector profitability and environmental sustainability will all be severely impacted for years to come. Law enforcement is uniquely positioned to take leadership roles in efforts to combat fraud in this “new normal.” Police officers are natural problem solvers that do so in environments with little resources and funding. Matching these capabilities with those within the private sector and NGOs could lead to instances of innovation labs crafting high-impact solutions to a crime that has forever changed because of COVID-19.
Cameron Field, BA, MSc, senior manager, BMO Financial Group; retired law enforcement officer, cameron.field@bmo.com
1 “Archived: WHO Timeline - COVID-19,” World Health Organization, April 27, 2020, https://www.who.int/news/ item/27-04-2020-who-timeline---covid-19
2 Wesley G. Jennings and Nicholas M. Perez, “The Immediate Impact of COVID-19 on Law Enforcement in the United States,” US National Library of Medicine, June 6, 2020, https://www.ncbi.nlm.nih.gov/pmc/articles/ PMC7275851/
3 “U.S. Department of Justice Reports on Heightened Enforcement Activities Against COVID-19 Related Fraud,” National Law Review, April 19, 2021, https://www.natlawreview.com/article/ us-department-justice-reports-heightened-enforcement-activities-against-covid-19
4 Ibid.
5 “COVID-19 Fraud,” Canadian Anti-Fraud Centre, https://www.antifraudcentre-centreantifraude.ca/ features-vedette/2020/covid-19-eng.htm
6 “Unmasked: International COVID-19 fraud exposed,” Interpol, April 14, 2020, https://www.interpol.int/en/ News-and-Events/News/2020/Unmasked-International-COVID-19-fraud-exposed
7 “Project PROTECT: Public Service Renewal in Action,” Financial Transactions and Reports Analysis Centre of Canada, https://www.fintrac-canafe.gc.ca/emplo/psr-eng; “United for Wildlife Taskforces,” Royal Foundation, https://royalfoundation.com/programme/private-sector/
8 Lawrence E. Cohen and Marcus Felson, “Social Change and Crime Rate Trends: A Routine Activity Approach,” American Sociological Review, August 1979, https://www.jstor.org/stable/2094589?seq=1
9 “COVID-19 cyberthreats,” Interpol, https://www.interpol.int/en/Crimes/Cybercrime/COVID-19-cyberthreats
10 “Coronavirus Updates,” Financial Crimes Enforcement Network, https://www.fincen.gov/coronavirus
11 “Statutory Partnerships and Responsibilities,” Ministry of Justice, November 2013, https://assets.publishing. service.gov.uk/government/uploads/system/uploads/attachment_data/file/389746/statutory- partnerships.pdf
12 The International Association of Chiefs of Police, https://www.theiacp.org/
13 “National Economic Crime Centre,” National Crime Agency, https://www.nationalcrimeagency.gov.uk/ what-we-do/national-economic-crime-centre
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