Global Financial Integrity

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Enhancing National Security by Reimagining FinCEN

In the spring of 2020 David Lewis, the Executive Secretary of the Financial Action Task Force, was asked to grade the effectiveness of the global anti-money laundering fight. “Everyone,” he said, “is doing it badly.” This withering assessment of anti-money laundering (AML) efforts, coupled with the fact that the US dollar and the American financial system are magnets for illicit money from around the world, provided Global Financial Integrity (GFI) the impetus to assemble a group of AML experts in late 2020, for a series of in-depth discussions on what the Biden administration can do to address this critical national security risk.

The participants, from government, industry and academia, were asked to (as much as possible) leave their knowledge of budgets and inside-the-beltway politics aside and propose innovative ideas which would, if implemented, create an approach to money laundering that would set the gold standard. Naturally, the Financial Crime Enforcement Network (FinCEN), given its unique AML role, was the focus of the deliberations. GFI has taken the wide array of suggestions made by the participants and has distilled them into the following recommendations:

  1. Give the FinCEN Director a seat on the Deputies Committee of the National Security Council (NSC) to raise the agency’s stature within the national security community.
  2. Create in FinCEN a National Anti-Money Laundering Data Center (NALDC) for advanced data collection, synthesis, analysis and distribution to law enforcement for AML activity.
  3. Establish a “Manhattan Project” to identify, develop and operationalize state of the art technologies needed to fulfill the technology needs of a NALDC.
  4. Launch within FinCEN the National Anti-Money Laundering Training Center (NALTC) which will be an anti-money laundering knowledge and education hub for FinCEN staff, financial institution regulators, law enforcement at the federal, state and local levels and for state and federal prosecutors.
  5. Create a Strategic Analysis Team to examine emerging and long-term trends in money laundering methods and computer technologies to counter those threats.