NEWS: Yesterday was World Elder Abuse Awareness Day, which has been commemorated on June 15 every year since 2006. The day provides an opportunity for communities around the world to promote a better understanding of abuse and neglect of older adults by raising awareness of the related cultural, social, economic, and demographic factors that can lead to elder abuse. Elder abuse affects at least 10% of older adults each year in the U.S.
The Financial Crimes Enforcement Network (FinCEN) issued Advisory FIN-2022-A002 yesterday to alert financial institutions to the rising trend of Elder Financial Exploitation (EFE) targeting older adults. The Advisory highlights new EFE typologies and red flags since FinCEN’s 2011 Advisory and includes case studies and common elder scams examples.
Credit unions are uniquely situated to detect possible financial exploitation through their relationships with older members. They therefore play a critical role in helping to identify, prevent, and report EFE to law enforcement and their state-based Adult Protective Services agencies. The information contained in this advisory is to remind credit unions of their BSA reporting obligations and provide directions to credit unions that suspect EFE activity.
SAR Filing Instructions
When filing a SAR, financial institutions should provide all pertinent available information about the activity in the SAR form and narrative. Reporting on how perpetrators of EFEs communicate with and target older adults is also useful to law enforcement investigations. FinCEN requests that financial institutions reference this advisory by including the key term “EFE FIN-2022-A002” in SAR field 2 (“Filing Institution Note to FinCEN”) and the narrative to indicate a connection between the suspicious activity being reported and the activities highlighted in this advisory.
Financial institutions that suspect EFE activity should also mark the check box for Elder Financial Exploitation (SAR Field 38(d)). FinCEN first added an “Elder Financial Exploitation” checkbox to the SAR Form in 2012 and encourages financial institutions to mark the box when filing an EFE-related SAR. For authorized federal, state, and local law enforcement, the checkbox makes it easier to locate and analyze BSA data related to EFE as detailed above.
Financial institutions should include any and all available information relating to the account and locations involved in the reported activity, identifying information and descriptions of any legal entities or arrangements involved and associated beneficial owners, and any information about related persons or entities involved in the activity. Financial institutions also should provide any and all available information regarding other domestic and foreign financial institutions involved in the activity; where appropriate, financial institutions should consider filing a SAR jointly on shared suspicious activity.
Financial institutions wanting to expedite their report of suspicious transactions that may relate to the activity noted in this advisory may call the Financial Institutions Toll-Free Hotline at (866) 556-3974 (7 days a week, 24 hours a day).
The Advisory also includes information on Other Relevant BSA Reporting Requirements, 314(b) Information Sharing, Rapid Response Program, and Other U.S. Government EFE Reporting Options. Questions regarding the contents of the Advisory should be addressed to the FinCEN Resource Center.