FinCEN enters convergence era with major reorganization, tears down “information silos”

The US Financial Crimes Enforcement Network announced yesterday one of the most significant reorganizations of its 23-year history. The reorganization, now effective, is designed to tear down “silos,” increase efficiency and facilitate information sharing between FinCEN, the financial institutions it regulates and the many federal and state law enforcement agencies that benefit from its data.

Until yesterday, FinCEN and its more than 300 employees were housed in “vertically integrated divisions” organized by the constituents they served. The Treasury Department bureau had separate divisions to serve law enforcement, oversee financial institutions, and support and work with its international partners, including counterpart financial intelligence units in other nations. Under its old structure, each FinCEN division had its own analysts, policy specialists, liaison and enforcement specialists.

FinCEN will now reorganize its staff and units by job function and create six new divisions – Intelligence, Enforcement, Policy, Liaison, Technology and Management. The FinCEN staff will work in divisions that match their job role. All financial intelligence analysts will be located in the Intelligence Division, policy specialists in the Policy Division, and so on.

The reorganization is intended to break through the agency’s “informational silos,” allowing financial intelligence to “cross-pollinate” and providing “better, more rapid response” to requests from law enforcement and other constituents, according to FinCEN’s Director of Public Affairs, Steve Hudak.

FinCEN Director says restructuring ‘good for all stakeholders’

When compared with the previous structure, the new FinCEN agency chart displays a significantly more streamlined and simplified organization. In an interview with ACFCS, FinCEN Director Jennifer Shasky Calvery pointed to two primary motivations behind the agency’s revamp.

“The first is that FinCEN is seeking to be as efficient as possible,” she said. “We’re a small organization for the broad set of responsibilities we carry, and we have to find ways to maximize staff and resources.”

“The second reason is that FinCEN serves as a bridge between multiple stakeholders, and they don’t always speak the same language,” she continued. “Law enforcement and financial institutions often speak right past each other. When we’re putting out policy, when we’re putting out intelligence, we want to ensure we’re putting it out in the proper language, and this reorganization is a way to do that.”

Shasky Calvery also stated that the reorganization is intended to meet the needs of financial institutions more effectively as well, with an enhanced “help desk” and BSA resource center.

“One of the common things we hear from institutions is, ‘we could do better if we are provided more information,” she said. As an example of how the reorganization might help funnel information to financial institutions, Shasky Calvery indicated that all intelligence analysts, including those serving law enforcement and the private sector, would now be housed in one office. This would allow details on emerging financial crime trends spotted on the law enforcement side to move rapidly to the private sector, without having to pass through multiple layers and departments.

Restructuring part of wider effort to enhance data analysis, trend-spotting at FinCEN

Enhancing FinCEN’s capabilities to spot new and trending forms of financial crime as they develop has been a recurring theme in a number of the agency’s recent initiatives. Last year, FinCEN issued a drastically expanded and redesigned Suspicious Activity Report, combined with a new mandatory electronic filing system.

That SAR was intended in part to capture more specific data on financial crimes in closer to real time, FinCEN officials said at the time of the form’s release. FinCEN also recently completed a multi-year overhaul of its IT and technology infrastructure, providing it with faster and more advanced data analytic capabilities.

FinCEN combats money laundering and promotes national security through the collection, analysis, and dissemination of financial intelligence, including the “Suspicious Activity Reports” filed by a wide array of US financial institutions.

The agency, which reports to the Office of Terrorism and Financial Intelligence at the US Treasury, issues and administers Bank Secrecy Act regulations, and imposes penalties for non-compliance.