FinCEN’s Advisory on Cyber-Events and Cyber-Enabled Crimes

The ACAMS Carolinas Chapter event “Advisory on Cyber-Events and Cyber-Enabled Crime,” held at the Fifth Third Center in uptown Charlotte on March 9, 2017, was a success. More than 100 people from over 25 firms across the Carolinas region were in attendance.

Special guest, Tim Bhatt, CISO at Ally Financial, kicked off the program with an overview of cyber risks. Bhatt engaged the audience in the discussion and raised some interesting questions regarding cyber security in today’s technologically advanced world.

Next, Paul Dougherty (Fifth Third), Kelley Chamberlain (Wells Fargo) and Carlos Orel (TD Bank) led a panel discussion on how to incorporate cyber-event data into anti-money laundering (AML) operations. Each panelist brought a unique perspective to the table. Dougherty initiated the conversation by discussing the FinCEN Advisory issued to financial institutions in October 2016 and the four components of it:

  • Reporting cyber-enabled crime and cyber-events through suspicious activity reports (SARs)
  • Including relevant and available cyber-related information in SARs
  • Collaborating between the Bank Secrecy Act/anti-money laundering (BSA/AML) units and in-house cybersecurity units to identify suspicious activity
  • Sharing information, including cyber-related information, among financial institutions to guard against and report money laundering, terrorist financing and cyber-enabled crime 

All of the panelists stressed the importance of communication between IT departments and AML groups and discussed the efforts to create a more formalized process to achieve this at their institutions.  There was also dialogue about the interest regulators are taking in banks’ efforts around cyber-events and cyber-enabled crime and the positive feedback received from law enforcement regarding the work being done at financial institutions to aid investigations, identify criminals, and disrupt and dismantle criminal networks.

Attendees enjoyed refreshments and networking immediately following the event.

If there was any information provided during the event about which you would like to know more, please contact us at

The Carolinas Chapter would like to thank the event speakers for their support:

  • Tim Bhatt, CISO, Ally Financial
  • Paul Dougherty, Fifth Third Bancorp
  • Kelley Chamberlain, Wells Fargo
  • Carlos Orel, TD Bank

Leave a Reply