Evaluate the 360 Degree Risk-Based Investigations Model. Write a 3-4 page Assessment Explaining: Investigation Essay, U.S.

Topic For Writing An Investigation Essay

Evaluate the 360 Degree Risk-Based Investigations Model. Write a 3-4 page assessment explaining each step of the model and how it relates to what you have learned thus far in this course.

For example,

1. Step 1: Trigger the Event explain the sources of investigation that would trigger an event (i.e transaction monitoring or law enforcement) and how this is important for an investigator as they begin their investigation.

2. Explain Step 2 and the importance of knowing your customer.

3. A complete similar analysis for the remaining steps. Using real-life case examples is a good way to explain these steps as well.

4. Finally, tell me if you think this model is effective for conducting an investigation. Why/why not? Defend your argument with relevant examples.

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Sources of Investigation

Investigations can be initiated by a financial institution proactively monitoring for potentially suspicious activity, regulatory recommendations, negative news, or from a subpoena from law enforcement. No matter how the investigation was initiated, the process for analyzing the transactions will be the same.

Investigations may be initiated from the following:

  • Financial institution proactively monitoring potentially suspicious activity
  • Regulatory recommendations
  •  Transaction-monitoring rules designed to alert for potentially suspicious activity
  • Referrals from customer-facing employees such as tellers, branch managers, or business bankers
  • Information obtained from internal hotlines
  • Negative news
  • Receipt of governmental subpoenas or search warrants

As an Investigator, I initiated investigations as a result of all of the above. Some of the most interesting cases were from the receipt of a governmental subpoena. These cases were typically high-profile (i.e. terrorist financing, Ponzi schemes, drug trafficking) and always required an in-depth analysis of transactional activity for a time period of at least two years.

Always remember that the source of the investigation will help you with the beginning stages of your analysis. For example, if a referral was made by a bank teller, you would want to speak with the teller to determine if he/she can provide additional information. If the referral was from law enforcement, you should speak to the agent to determine if he/she can provide you with information on what they are looking for as this can help you when reviewing the customer’s account.

Utilizing Open Source Information When Conducting Investigations

When conducting an investigation, you will not rely solely on the information maintained at the financial institution. Investigations need to consider external sources such as public records databases and social media which can yield a great deal of information on a customer.

Consider the number of information individuals put on social media sites such as Facebook and LinkedIn which can be incriminating. For example, say you are looking into a customer who has been linked to drug trafficking. You review his Facebook profile because it is not private, and you see pictures of luxury vehicles, expensive jewellery, and constant international travel to places such as Mexico and Colombia.

While you cannot say for certain the individual purchased these items from money received from drug trafficking, the activity is potentially suspicious and should be added to your Suspicious Activity Report (SAR) for law enforcement to review further. In my current position, we use publicly available social media profiles to map out large criminal networks as the suspected individuals are typically friends with one another on social media.

Law enforcement loves information likes this because it helps them connect co-conspirators! When using the internet to search for additional information, the investigator must use credible sites and verify the information from more than one source. Using a variety of search engine and news articles is a good way to do this. The information should be complemented by documentation maintained by the financial institution.

Conducting an investigation requires the investigator to be cognizant of the source of the referral as this will set the stage for the beginning of their analysis. An investigator must be prepared to solicit information from bank personnel in other lines of business as well as law enforcement in order to obtain a thorough understanding of the activity in question. Additionally, investigators need to consider external sources when conducting an investigation as they will likely obtain information on the customer that was not available to the financial institution.

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