On October 24, 2024 the New York ACAMS Chapter hosted an event titled Financial Frontlines: Strategies in the Fight Against Human Trafficking, which was sponsored by Moody’s. The discussion included the following panelists pictured below from left to right: Meryl Lutsky, Esq. (Chief Operating Officer & General Counsel, T&M USA, LLC); Drew Bach (First VP – BSA Officer, First National Bank of Long Island); Jill DeWitt (Senior Director, Industry Practice Lead, Financial Crime Compliance, Moody’s); Pawneet Abramowski (Event Moderator - CEO & Founder, PARC Solutions); and Sabrina Chen (Global Head of AML Customer Risk & Data Science Senior Lead, Citi).
A theme that ran throughout the discussion was the prevalence of human trafficking in our communities and throughout our financial system. Regardless of its prevalence, discussing human trafficking is often avoided because it’s uncomfortable to openly acknowledge. Like all financial crime, financial institutions are in a key position to detect and report human trafficking, and therefore it’s critical for bank employees to be trained on activity indicators.
Typologies and red flags can be identified through multiple different controls. General inherent risk exposure can be assessed, for example, through exposure to higher risk geographies – certain countries are more susceptible to this crime based on looser controls and lesser penalties. Much of the discussion was focused on red fags that are identified in person (e.g., at branches). The training of front-line staff is therefore critical to the detection and reporting of human trafficking activity. Training should entail, for example, law enforcement notification procedures in addition to internal referral processes because it's critical to empower branch personnel to escalate potential activity in the moment. Branch referrals can ideally be coupled with detection through transaction monitoring to build a more comprehensive case that involves money laundering.
Financial institutions should aim to detect and report the activity through multiple avenues and to build a case against the network. Only notifying law enforcement of in-person branch activity could be less impactful due to the fact that many victims are not willing to cooperate with financial institution staff or law enforcement. A significant emphasis was placed on strong partnership with local law enforcement to effectively prevent and detect human trafficking activity. The panelists reminded the audience that all communities are impacted by human trafficking, so financial institutions should understand from local experts what activity looks within their specific community.
Regardless of general discomfort regarding discussing the prevalence of human trafficking, the panel’s passion for disrupting this activity was contagious, as the conversation carried into the networking session held afterwards.
تعليقات