Some of you might remember when the Rubik’s Cube was all the rage. In my house, we had all sorts of puzzles and board games to keep us kids entertained, one of which was the aforementioned Rubik’s Cube. Solving the Cube requires all the colors to be lined up on each side. My family is a bit competitive and when we received the Rubik’s Cube, we all wanted to be the first one to solve it; however, my little sister decided to be creative in order to be more effective. Instead of twisting and turning the many sides to line up the colors, my sister decided to peel off the colors from each section and restick them on the correct side so all the colors would match. She then went on to claim that she had solved the Rubik’s Cube puzzle before anyone else.
Though my sister’s method was effective in accomplishing her goal, it did come with complications. For example, once the stickers were peeled off, some of the adhesive was not strong enough to maintain the colors on the Cube and if anyone else decided to play with the Rubik’s Cube, some of the stickers would fall or get stuck on other surfaces. Such can be the case when writing suspicious activity reports (SARs). While an anti-financial crime (AFC) professional is trying to be effective and write the required SARs on the numerous illicit or suspicious activities that pass through their financial institutions, their seemingly well-crafted SAR can become unstuck in the hands of an investigating law enforcement (LE) agency if they are not careful. There are steps that the AFC professional can implement to make their SARs more effective, especially for LE. The lead article “Soaring to Effective SARs” outlines seven steps that—when implemented—can lead to effective SARs. The author, Nancy Lake, states “the entire purpose of the AMLA is to ensure the effectiveness of the BSA in the fight against money laundering and terrorist financing.” The Anti-Money Laundering Act of 2020 (AMLA) has ushered in the era of effectiveness in the fight against financial crime and one of the sections in the AMLA describes fostering greater collaboration between the public and private sectors. Read on for more guidance on effective SAR writing.
Similar to the multiple sides of the Rubik’s Cube, this edition is comprised of different ways to partner with LE that —when effectively implemented—result in strong partnerships across the public and private sectors. Cameron Field discusses on page 40 how effectively matching LE capabilities with the private sector can assist in tackling post-pandemic fraud; “The New Age of Investment Fraud” emphasizes the need for LE to continue to educate the public on emerging threats, specifically in the fintech industry; and “Professional Matchmaking: Harmonizing Law Enforcement Investigations” incorporates an interview with Christopher Ruzich of Standard Chartered America’s Financial Crime Compliance team where he describes how the “matchmaking 101” methodology can assist FIs in connecting LE agencies who share the same goal of catching the targets of investigations, thus building relationships to deter financial crime.
Like my sister, there are numerous ways for FIs and LE to be effective, but to be truly effective, it must be long lasting. This can only be accomplished through collaboration, partnerships and a common goal, which, if I may be so bold, is to stop financial crime.
Finally, I urge you to take a moment to vote for the ACAMS Today Article of the Year. There were many wonderful, insightful and inspiring articles from the past year. You can view the nominees by visiting the following link: acams.org/conferences/LasVegas/awards.
Karla Monterrosa-Yancey, CAMS
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