Elder Financial Exploitation Red Flags

Elder financial exploitation (EFE) is the most common form of elder abuse and is a real problem. In most cases, the victim is either unaware that someone is exploiting their finances or they choose to not come forward out of fear, embarrassment or a lack of resources. EFE is something that financial institutions need to be aware of and keep an eye out for since they are in a unique position. A 2022 FinCEN Advisory on EFE (FIN-2022-A022), provided a listing of behavioral red flags and financial red flags that could signal EFE. A few examples of these red flags include:


  • A caregiver or other individual shows excessive interest in the older customer’s finances or assets, does not allow the older customer to speak for himself or herself, or is reluctant to leave the older customer’s side during conversations.
  • An older customer appears distressed, submissive, fearful, anxious to follow others’ directions related to their financial accounts, or unable to answer basic questions about account activity.
  • A new caretaker, relative, or friend suddenly begins conducting financial transactions on behalf of an older customer without proper documentation.


  • Uncharacteristic, sudden, abnormally frequent, or significant withdrawals of cash or transfers of assets from an older customer’s account.
  • Closing of CDs or accounts without regard to penalties.
  • Debit transactions that are inconsistent for the older customer.

BSA Resources!


Amy Kudlacek

Amy brings many years of banking and compliance experience to Banker’s Compliance Consulting. She has worked for both large and small financial institutions and spent time working in every area of a bank. She started out as a teller in college and eventually became a branch manager. Her love, however, was always compliance. Amy began her career with Banker’s Compliance Consulting in 2000. Her knowledge and experiences have allowed her to develop a well-rounded and practical approach to regulatory compliance. Amy is CRCM certified, has a Bachelors Degree in Business Administration and is a graduate of the ABA Compliance School. Amy & her husband have two children at home and stay busy following their activities. They spend a lot of time in the bleachers!

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