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Financial Services Law Insights and Observations

FinCEN releases notice regarding online child sexual exploitation crimes

Financial Crimes SARs FinCEN Of Interest to Non-US Persons

Financial Crimes

On September 16, FinCEN issued a notice regarding an increase in online child sexual exploitation (OCSE) and provided financial institutions with specific suspicious activity report (SAR) filing instructions, noting some financial trends related to OCSE. According to FinCEN, there was a “147 percent increase in OCSE-related SAR filings between 2017 and 2020.” The notice provides that financial institutions should, among other things: (i) “reference only this notice in SAR field 2 (Filing Institution Note to FinCEN) using the keyword ‘OCSE-FIN-2021-NTC3,’” which should also be referenced to specify a relationship between the suspicious activity being reported and the activities in this notice,” and (ii) “select SAR Field 38(z) (Other) as the associated suspicious activity type to indicate a connection between the suspicious activity reported and OCSE activity and include the term ‘OCSE’ in the text box.” FinCEN requests that reporting entities utilize the Child Sexual Exploitation terms and definitions located in the Appendix of the notice when detailing suspicious activity. FinCEN also specifies the selections to be utilized if human trafficking and human smuggling is suspected.

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