Right here, right now: Taking action on financial crime paid Deloitte
, outlines reforms that can bolster the efforts of law enforcement in this area. These reforms can enhance the legal and regulatory framework and, when taken together, have the power to transform how society combats financial crime.
But there’s often no need to wait for governmental action. PPPs that address financial crime already exist in many countries—and if they haven’t yet, clearly an FI should take advantage of these agencies. Their ability to provide on-the-ground information about criminal behavior is invaluable. The United Kingdom’s Joint Money Laundering Intelligence Taskforce is just one PPP that has seen considerable success. Similar bodies exist in Canada, the United States, and Australia, to name a few.
Of top concern is to make sure data isn’t structured in a way that creates silos between units that flag criminal behavior. If an FI is not pulling all that data together or collaborating in a meaningful way across risk silos, it may miss critical insights. Even worse, the gaps among silos are, again, just the type of cracks in the foundation criminals are looking for.
A good example is the use of thresholds. In the fight against financial crime, rules and rules-based thresholds are essentially very blunt tools. They generate thousands of unproductive alerts with loads of time and effort put into investigating leads that essentially go nowhere.
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