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What is the FinCrime Network?

FinCrime is sponsored by various state bankers associations and the Georgia Credit Union League. It is open to their member financial institutions and law enforcement officials. FinCrime is a network of financial institutions sharing information in a database on fraudulent activity. The result-shared aggregated data identifies and links criminal groups to their acts. FinCrime's focus is to improve financial institutions' ability to detect and prevent fraud losses and to assist law enforcement in the prosecution of criminals.

How does FinCrime work?

FinCrime provides a communication vehicle for financial institutions and law enforcement. FinCrime functions as a clearinghouse of information where each participant submits fraud data into a central depository. FinCrime allows users to search the database of fraud incidents to find incidents that have data in common with their own cases.

Who can use FinCrime?

FinCrime can be used by any law enforcement agency, financial institution or approved retailer. All users must be authenticated and approved by the network administrator of one of the sponsoring associations.

What does FinCrime accomplish?

By providing a confidential and secure way to share information about fraudulent transactions, participating financial institutions are made aware of fraudulent activity in their area, usually sooner than they would be able to identify it by themselves. This early awareness allows them to take action to prevent fraud losses. Also, the shared database provides opportunities to build fewer but larger "multi-institution" cases out of smaller individual losses, helping financial institutions and law enforcement officials focus on organized crime and repeat offenders. This more efficient use of law enforcement resources results in overall loss reduction for financial institutions, as professional criminals find financial institution fraud more difficult, more risky and less profitable to pursue.

Does FinCrime conflict with FinCEN SAR reporting requirements?

The Bank Secrecy Act prohibits a financial institution, its directors, officers, employees or agents from disclosing to any person involved in the transaction that a SAR has been filed. SARs must be filed only on certain transactions that are suspicious in nature, involve potential money laundering or violations of the Bank Secrecy Act when aggregate dollars involved in the transactions exceed reporting thresholds. The BSA does not prohibit information contained in a SAR to be shared on a voluntary basis with other persons or law enforcement, so long as the fact that the SAR has been filed is not disclosed.

How will law enforcement benefit?

First and foremost, FinCrime helps consolidate numerous small, individual victim cases into fewer, stronger "multi-victim" cases. This focuses law enforcement on perpetrators that are doing the most serious damage to the industry as a whole and allows them to use their limited resources more effectively.

What implications does the Fair Credit Reporting Act (FCRA) have on FinCrime and FinCrime Participants?

The FCRA contains certain exclusions from the definition of “consumer report.” One such exclusion is any report containing information solely as to transactions or experiences between the consumer and the person making the report. Under that exclusion, information published by a member of FinCrime that relates solely to the transactions or experiences between the consumer and the person making the report would not be a consumer report within the meaning of FCRA, and such a report will not violate FCRA. Accordingly, members of FinCrime should limit the information published to specific experiences between the consumer and the financial institution publishing the information on FinCrime.

Does FinCrime Participants' information contribution conflict with the Gramm-Leach-Bliley Act (GLBA)?

GLBA generally requires protection of the security and confidentiality of customer/member records and information. However, GLBA contains certain exceptions, including § 502(e)(3) which provides as follows: “GLBA shall not prohibit the disclosure of nonpublic personal information to protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liability.” Since FinCrime members will provide information that is for the purpose of protecting or preventing actual or potential fraud, unauthorized transactions, claims, or other liability, such sharing of information is specifically permitted under GLBA.

How is data entered into the system?

Individual cases can be entered into the system via a form on the web site, or multiple cases can be loaded into the FinCrime database via batch upload process.

How can I search the data?

The real power of the system comes from the ability to search the data in a number of ways. The user may search the database on almost any field or combination of fields, this includes any of the names on the financial instrument used, any of the information contained on the ID used, date, location and type of crime.

Can anyone change the data I have loaded?

With the exception of "follow up" information, only the person that posted the incident has the ability to modify the information that has been posted. Follow up information can be added to an incident by anyone, but is intended to be used by law enforcement to add additional information as the investigation proceeds. The owner of the incident is notified by e-mail when follow up information is added.

What data is stored?

Data stored includes information on the date and type of crime, information from the financial document used, all relevant information from the ID used by the suspect, as well as information regarding the investigating officer/agency.

Does the system help me contact other investigators?

The name and contact information of the person posting the incident as well as the investigating officer, along with the case number are stored in the database.

What else does the system do to help me match incidents?

At the time that an incident is posted to the network, the network will automatically check the incident against all other incidents in the database. If a match is found with another incident both you and the person that posted the matching incident are notified of the matching elements via e-mail.

The system also contains a feature that will allow you, or law enforcement officials to link two incidents together when the system may not otherwise be able to do so. This is useful when one the incidents involves someone using a known alias.

Does the system distinguish or denote victims’ names?

An indicator can be placed on all name fields within the database to show that this person is the victim of the crime rather than the perpetrator.