| Gangs are engaged in complex and sophisticated financial crimes. These crimes involve both law enforcement and financial institutions. Both law enforcement and financial institutions need effective information to identify and disrupt the financial crimes gangs commit. Law enforcement has information that would allow financial institutions to become a great provider of actionable intelligence if it was provided to them. Financial institutions do not have the proper information to identify clients who are gang members or associates and are at a higher risk of conducting money-laundering activities. Not being able to properly risk rate customers allows for potential missed Suspicious Activity Reports (SAR). Missing SARs prevent information that can be used by law enforcement to develop actionable intelligence. The Office of Foreign Assets Control (OFAC) has provided a model to demonstrate that by sharing information with financial institutions, the private sector can aid in the disruption of the movement of illicit funds. Financial institutions need effective information to properly risk rate customers, identify unusual activity, and report activity indicative of money laundering. Four key recommendations were developed that will allow financial institutions to identify gang members and associates who are clients and effectively report their suspicious activity indicative of money laundering. By effectively reporting suspicious activity, law enforcement obtains more actionable intelligence to combat gangs. Keywords: Economic Crime Management, Dr. Shannon Johnson, Know Your Customer (KYC), Sanctions, Gang Databases, Fusion Centers, Gang Task Force. |
