This Week in AML

Suspicious Activity Beyond the SAR

This week the Department of Homeland Security added an item to its website entitled “if you see something, say something.” The item discusses how individuals can report suspicious activity. John and Elliot look at some of the red flags identified by the DHS and discuss the impact of viewing suspicious activity reporting as something beyond the responsibility of entities regulated under the Bank Secrecy Act.



Suspicious Activity Beyond the SAR TRANSCRIPT


Elliot Berman: Hi, John, how are you this week?


John Byrne: Good, Elliot. How are you doing?


Elliot Berman: I'm okay. So, this week I noticed that the Department of Homeland Security updated a part of their website related to reporting suspicious activity. It's under the banner of, "if you see something, say something.", which I think is a phrase that they've been using for a number of years now in airports and other large venues to encourage people to identify abandoned backpacks and you know, other things like that. 


I wondered if you saw those updates to the website.


John Byrne: I did. Another great example of the value that government agencies can have in terms of outreach [and] communication, especially now when we're dealing with all sorts of challenges, including the obvious challenge of domestic terrorism and the not knowing our neighbors, perhaps as well as we should. So I think what struck me [was] we're very used to in our community of reporting suspicious activity. Obviously, that's sort of what everything is based on under the Bank Secrecy Act, but the number of things that they list as possible.


Indicators of suspicious activity, and some that they said are not, you know, religion and race, that sort of thing. But the ones that they said are, I thought it was a not only a comprehensive list, but it's in an infographic, you can download it and make it available to your employees, your firm, and that sort of thing.


So there's a number of examples. In our world, one is recruiting and financing. So just some sort of funding activity or recruiting people to do that. But other things that I know if we talked through this long enough, we would say, oh yeah, that makes sense.


That's people that are surveilling locations longer than they should, you know, attempted breach of areas that are restricted. So it's not only a comprehensive list, but I think hopefully a very useful list to folks that are not in our world but just need to be aware of what's going on around them.


Elliot Berman: Yes. I agree. I thought [the] list was very interesting. You know, again, coming back to what happens in our community, we encourage the same thing. We may not use the same phrasing, but for example, all of our customer-facing colleagues are encouraged to report through some internal mechanism. It varies from company to company, anything that they see that suspicious. In our surveillance efforts for suspicious activity, it's not just transactional. Sometimes it appears in other ways and, and we've talked about this on various webinars and other things, examples like in the Elder Abuse and Human Trafficking area, there are things that can happen that would be indications of people not acting independently and being go coerced and things like that.


So, I thought it was interesting that the DHS is actively trying to get this mindset extended to everybody, and I think [they're] doing a very good job of it. So before we forget, if you go to https://www.dhs.gov/see-something-say-something, you'll get to one of the pages, and then you can workaround.


They're really talking about it from a campaign perspective, encouraging companies, nonprofits, schools, and things like that to download the infographics and post them and talk about them. These are good resources, but I think they're good resources even internally within the community because they kind of come at it, as you mentioned, from a slightly different angle.


John Byrne: Right. If you go through the map of the US, they're not asking you to report this activity to Homeland Security. They're saying report it locally. For example, I live here in Virginia, and if you click on Virginia on the map, it says to contact the Virginia Fusion Center. In our state, that's a coordination of federal, local, and private sector partners.


Then they tell you how to report suspicious activity, and this won't be anything new to our community, but who did you see? What? When did you see it? Where? Then, of course, why do you believe it's suspicious, and they certainly give you enough information to make a determination of at least what boxes you're checking to say that something is you think could be suspicious, then leaving it to the experts to follow up.


Elliot Berman: Yeah, it's interesting. I live in Wisconsin, and I clicked on Wisconsin, and here, you know, they say if it's an emergency, call 911. Otherwise, they give an 800 number. Or a toll-free number, but you're actually reaching the Wisconsin Statewide Intelligence Center.

So again, you know, not at the county level, but really a coordinated state level, kind of thing. So, yeah, I was very impressed with the quality of the materials, the thoughtfulness. It was interesting to have a perspective that isn't strictly from the financial transaction perspective.


John Byrne: Yeah, and for those of our listeners that are sports fans, you'll recognize the bottom of some of the pages. Some of the previous PSA's that they've done, for Major League Baseball or the NFL, the clips that you've seen at stadiums, the see something say something statements that are pieces that have been going out for the past couple of years.


So this is taking this all to a broader level. As I said, the infographic is, I think, extremely useful as a training tool.


Elliot Berman: Yes. Agreed. So, I'll do the shameless plug again this week. If you like this [podcast], certainly join us on Fridays. You can find us on SoundCloud, Apple Podcast, or wherever you get your podcasts.


We also have other things in the AML Conversations podcast series and some other great materials in other formats on our website at www.amlrightsource.com. So, John, you have a great weekend, and I will see you next week.


John Byrne: Thanks Elliott, stay safe. See ya.


Elliot Berman: Bye-bye.