FinCEN Notice

On September 16, 2021, the Financial Crimes Enforcement Network (FinCEN) issued FIN-2021-NTC3 to call attention to a troubling rise in Online Child Sexual Exploitation (OCSE) Crimes.  According to multiple law enforcement authorities, the lockdowns associated with the COVID-19 pandemic have contributed to the rise in OCSE due to a number of factors, including:

  • Increased internet usage by children who are spending more time online, both unsupervised and during traditional school hours;
  • Restricted travel during the COVID-19 pandemic resulting in more sex offenders being online; and,
  • Increased access to and use of technology, including encrypted communications, bulk data transfer, cloud storage, live-streaming, and anonymized transactions.

Additionally, there has been a notable rise in “sextortion” of minors, who are coerced/exploited into exchanging sexual images by OCSE offenders who “groom” minors to post such content for money.  FinCEN reviewed OCSE-related Suspicious Activity Reports (SAR) and noted that there was an increasing usage of convertible virtual currency (CVC), peer-to-peer mobile applications, the darknet, and anonymization/encryption services to avoid detection.

In order to better identify and track these types of cybercrimes, FinCEN wants to remind financial institutions to provide all pertinent and available information in the SAR narrative and attachments.  They have provided specific filing instructions for OCSE related SARs.  There is also an Appendix included with helpful information as to terminology and definitions related to Child Sexual Exploitation Crimes.

If you are looking for additional training and resources, OCSE Crime and other cybercrimes will be addressed in our Virtual BSA/AML Compliance Conference on November 10, 2021.


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