July 5th started out as a quiet day at America's Credit Union, a $400 million institution in the Puget Sound area. Then the Friday took an unlikely turn.
Jen Lamont, Bank Secrecy Act and fraud manager at ACU, got wind of a possible scam underway. A call center team member had taken a suspicious-sounding call from someone attempting to confirm a wire transfer. There were two parties involved and when Lamont reviewed the calls, she realized it was the same voice pretending to be two different people. But she did not know anyone at the two banks to which the wires had been sent.
"I didn't panic, but I went into 'solve the problem as quick as possible' mode," Lamont said in an interview.
She called Ian Mitchell, founder of human trafficking nonprofit The Knoble, who gave her contacts at both banks within five minutes.
"The contact at one of them saved me $21,000 that would have gone out the door 10 minutes later," Lamont said. "The fraudster was in one of his branches trying to get access to the remaining $21,000 ten minutes after he froze those funds."
The incident is an example of one of the hardest aspects of detecting fraud and other crime in banks and credit unions: recognizing when a transaction that a customer has apparently authorized is part of a scam.
"As fraud investigators, we've done an incredible job of preventing unauthorized activity," Lamont said. "Our biggest challenge is dealing with authorized activity from scam victims, people who have been targeted and lied to and manipulated by scammers. They're purchasing gift cards and doing wire transfers and setting up ACH payments."
"This is where collaborating with other financial institutions is beneficial," she said.
Joining a consortium
Lamont had heard of The Knoble from a friend and had met Mitchell at an Association of Certified Fraud Examiners conference.
The Knoble, which is based in Chattanooga, Tennessee, works with law enforcement organizations, banks and credit unions to detect human crime in four categories: human trafficking, financial scams, child sexual exploitation and elder financial exploitation. They share intel about investigations, and banks use that information to set alerts in their fraud detection and anti-money laundering software. For instance, past investigations have shown that certain patterns of payments to massage parlors and nail salons are indicators of human trafficking, and software can flag such patterns for fraud or money laundering investigators to review.
The group, which Mitchell founded in 2019, has worked with more than 600 banks.
"My personal opinion is that human crimes is kind of a blind spot in financial services," said Bob Shiflet, who has volunteered with The Knoble for the past year and formerly was a fraud executive at Wells Fargo, Bank of America and Citi.
"There are risk officers for every type of risk you can think of, whether it's money laundering or fraud or credit risk or operational risk," Shiflet said in an interview. "But there is kind of a blank spot for human crimes. Part of that is that organizations are very immature in terms of their thought process around human crimes."
There's no real financial impact to financial services around human crimes, Shiflet noted. But there is reputational risk, which he believes is growing with the understanding that most human crimes have a financial aspect, and that banks might be helpful in the overall effort to reduce it.
"When you talk about things like sextortion, when over the last year 45 teens have committed suicide because they're being extorted sexually on dating apps and Instagram, I think we get to a point there and say, well, how does the bank stop it?" he said.
The social networks and app providers hosting this activity have the first responsibility to do something, such as not showing contact lists and friend lists, he said.
"That's how this extortion happens – they say, I'm going to send these pictures to all the people" on the victim's contact list, Shiflet said. "But then the banks have no financial liability. In fact, they don't even know the stuff's going on. The big 'but' there is, you can educate the banks. There are things they can do to monitor for the steps of the crime."
For example, when opening an account for a minor, a bank could provide financial literacy and sextortion training, he said. Financial institutions could get the child's parents to opt in to monitoring their children's accounts for transactions that don't make sense or that are indicative of sextortion, he said.
Around 20 banks are participating in the second phase of The Knoble's Project Umbra, which works to detect signs of child exploitation in financial transactions, Mitchell said in an American Banker podcast that will air December 3.
Alongside banks, payment companies like Zelle, PayPal and Venmo, networks like Mastercard and Visa and social networks and application owners are all stakeholders in human crime, and all could be working to detect and prevent it, Shiflet said.
Then there's law enforcement, which gets information about crimes that should be fed back to the other stakeholders to help with prevention and detection. The Knoble brings all these stakeholders together to share information and compare notes.
"I think where you see organizations like The Knoble really make a difference is education, they put out so much information and opportunities to engage and to learn more," Lamont said. "They're taking experts from every facet of this industry and saying, Hey, what message do you want to get out? Because you've got this area of expertise that I think that the community could benefit from."
Lamont has participated in calls and meetings with members of The Knoble about topics like elder exploitation and labor trafficking. She has also hosted meetings with topics such as AI, deep fakes and using open-source intelligence to try to fight fraud, which is getting more complex.
Why banks need a human crime officer
In the American Banker podcast, Mitchell floated the idea that every bank should have a human crime officer.
"This human crime officer has a very similar role to that of an identity theft officer," Mitchell said. This person would report to the board about crimes of exploitation and how the institution is implementing controls to protect its customer base.
Appointing a human crime officer doesn't require a lot of investment, he said.
"There are people already existing in financial institutions all around the world that already want to do this job," Mitchell said. "So this empowers them a little bit and it will help the financial institution to justify some of the investment of time and potentially some data needed to advance the fight to protect people. That will advance us to the point where we have detection of child sex trafficking, human trafficking, child sexual exploitation scams and elder financial exploitation and it will be consistent across the industry."
At America's Credit Union, Lamont has designated herself the human crimes officer.
"The idea of a human crimes officer, a person with knowledge, education and a true passion for this is what it's going to take," she said, "alongside collaboration with other banks."
The concept of a human crimes officer dovetails with FinCEN's priorities, Lamont said.
"Our auditors are not holding us accountable to those priorities yet, but I do believe accountability is coming," she said. "At some point our auditors are going to ask us what we are doing to combat human trafficking and other human crimes." Having a human crime officer will show the organization is already on top of it, she said.
Shiflet said having a human crime officer at every bank would make it possible for fraud investigators to connect the dots between banks.
"I had a hard enough time doing that with fraud, but the one advantage I had was, at least there was someone in charge of fraud at each bank that I could call and start to connect the dots," he said. "I think there's much to be gained by appointing a human crimes officer, especially since there's no true financial liability at these banks for these crimes."
