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Financial Services Law Insights and Observations

FinCEN releases fact sheet on RRP

Federal Issues FinCEN Of Interest to Non-US Persons SARs Financial Crimes

Federal Issues

On February 14, FinCEN issued a fact sheet regarding its Rapid Response Program (RRP), which is “a collaborative partnership that leverages FinCEN’s relationships with law enforcement, U.S. financial institutions, and foreign financial intelligence units to help victims and their financial institutions recover funds stolen as the result of certain cyber-enabled financial crimes schemes, including business e-mail compromise.” According to FinCEN, in addition to providing information about the program, the fact sheet emphasizes that victims of cyber-enabled crimes, or victims’ financial institutions, need to file a complaint with law enforcement to start the RRP process. The fact sheet also provides guidance on, among things: (i) activating the RRP; (ii) suspicious activity reporting; and (iii) information for financial institutions sharing information. FinCEN noted that it assisted in the recovery of over $1.1 billion since the program started in 2015.