FinCEN Notice
On September 16, 2021, the Financial Crimes Enforcement Network (FinCEN) issued FIN-2021-NTC3 to call attention to a troubling rise in Online Child Sexual Exploitation (OCSE) Crimes. According to multiple law enforcement authorities, the lockdowns associated with the COVID-19 pandemic have contributed to the rise in OCSE due to a number of factors, including:
- Increased internet usage by children who are spending more time online, both unsupervised and during traditional school hours;
- Restricted travel during the COVID-19 pandemic resulting in more sex offenders being online; and,
- Increased access to and use of technology, including encrypted communications, bulk data transfer, cloud storage, live-streaming, and anonymized transactions.
Additionally, there has been a notable rise in “sextortion” of minors, who are coerced/exploited into exchanging sexual images by OCSE offenders who “groom” minors to post such content for money. FinCEN reviewed OCSE-related Suspicious Activity Reports (SAR) and noted that there was an increasing usage of convertible virtual currency (CVC), peer-to-peer mobile applications, the darknet, and anonymization/encryption services to avoid detection.
In order to better identify and track these types of cybercrimes, FinCEN wants to remind financial institutions to provide all pertinent and available information in the SAR narrative and attachments. They have provided specific filing instructions for OCSE related SARs. There is also an Appendix included with helpful information as to terminology and definitions related to Child Sexual Exploitation Crimes.
If you are looking for additional training and resources, OCSE Crime and other cybercrimes will be addressed in our Virtual BSA/AML Compliance Conference on November 10, 2021.
Published
2021/09/29
Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).