WASHINGTON — Members of NAFCU's board took the opportunity Dec. 5 to tour the headquarters of the U.S. Treasury Department's Financial Crimes Enforcement Network (FinCEN) headquarters in Virginia. The visit was highlighted by a discussion with FinCEN Director James H. Freis, Jr.

"During these times, when security and compliance issues are a high priority for credit unions, we greatly appreciate the time and effort Director Freis and his staff dedicated for our visit and to address our members' concerns," said NAFCU President Fred Becker.

Freis underscored how valuable the contributions of credit unions are to law enforcement agencies and FinCEN. Specifically, in reference to the Bank Secrecy Act, he highlighted four uses for the information by law enforcement agencies, FinCEN and other financial regulators: tip off, identifying information, trends and deterrence.

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Freis cited the fact that sometimes a teller or a loan officer's good instincts can, and do, result in the contribution of critical information that serves to set investigatory wheels in motion. He added when an investigation is already underway, the BSA information can add significant value by pointing to the identities of previously unknown subjects, exposing accounts and other hidden financial relationships, or unveiling items of identifying information. Stated NAFCU Chair John Milazzo: "It seems there are lots of opportunities for NAFCU and FinCEN to work together that would be mutually beneficial."

Moreover, Freis stated, law enforcement investigators, as well as FinCEN analysts, can use technology to examine the entire BSA information base more broadly. When expertly queried, the data unmasks trends and patterns that hold the tell-tale signs of criminal or terrorist networks and emerging threats. Ultimately, he said BSA regulations has a deterrent effect on those who would abuse the financial system. The certainty of a Currency Transaction Report and the mere possibility of a Suspicious Activity Report forces criminals to behave in risky ways that expose them to scrutiny and capture.

"The robust nature of the data is very impressive," commented NAFCU Board Member Cutler Dawson, CEO of Navy Federal Credit Union.

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