The Agencies recent Interagency Statement on Elder Financial Exploitation (EFE) pointed out that supervised institutions may voluntarily file Suspicious Activity Reports for suspicious activities and suspected violations of law or regulation that otherwise do not meet the requirements for mandatory filing, which may include suspicious activities related to elder financial exploitation. It also pointed out that, in some states, reporting suspected EFE to other designated agencies is mandatory. EFE is a horrible crime that has great consequences for our elderly population. At a minimum, you need to ensure you are meeting the requirements of your state, if any, and also any suspicious activity reporting as part of your BSA/AML program. Outside of that, a lot of institutions who wish to report suspected EFE start with local law enforcement and then adjust depending on the response they get.
Appendix A of the Interagency Statement includes a great compilation of resources related to EFE. There are links to various reports, research and recommendations broken down by regulatory agency as well as Federal and State resources the financial institutions are encouraged to share with account holders for education purposes.
Published
2025/04/07
