Page 52 - ACAMS-Today-V20N3

[ PRACTICAL SOLUTIONS ]
Crime is nearly always about the money
With this prevailing propensity of only seriously considering the financial aspects at the mid to higher levels, a far larger potential sector of law enforcement has been left out of the BSA/AML efforts. Simple math indicates that law enforcement investigative resources at these mid or higher levels are far too limited to be truly effective in taking full advantage of all the information and intelligence that a greater majority of the SARs and other Bank Secrecy Act (BSA) data is now providing.
These SARs should not be falling on deaf ears. Too often elderly fraud, human trafficking or drug dealers fueling the overdose crisis are part of these SARs. Although they may provide little investi- gative interest from a higher-level perspective, there are other sectors of law enforcement that should, at a minimum, be aware of them. However, this prevailing propensity has also resulted in too few of that larger sector of law enforcement not being trained to recognize the investigative virtues found in the BSA/AML efforts.
So far in the public-private partnership envisioned by the BSA, law enforcement has always been expected to take the lead. While this may be a productive relationship from a macro perspective, on the micro perspective the private sector’s investment in the earlier recog- nition of the illicit money typologies has now likely exceeded that of law enforcement. Perhaps the boost that the partnership needs may be the private sector taking an increased role in helping law enforcement catch up?
Although “follow the money” is at the core of the BSA and is regularly touted as an indis- pensable and universal investigative strategy, it is too rarely part of more general law enforcement investigative trainings and strategies. Crime is nearly always about the money. That needs to be a larger part of those trainings and strategies. Promoting financial investi- gative literacy as part of ground-up philosophy may be at the core of the BSA/AML sector reaching its true potential.
Steve Gurdak, CAMS, supervisor, Washington Baltimore HIDTA, Northern Virginia Financial Initiative (NVFI), VA, USA, sgurdak@wb.hidta.org
Disclaimer: The views expressed are solely those of the author and are not meant to represent the opinions of the W/B HIDTA.
52 [ JUNE-AUGUST 2021 ]