Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor

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3/5/2005 USA PATRIOT Act Monitor News Release: FinCEN Revises Strategic Plan for 2006-2008

A three-year strategic plan, for 2006 through 2008, has been released outside of FinCEN's "regular strategic planning cycle," perhaps in part because of the increased funding provided the agency by the Intelligence Reform and Terrorism Act (discussed in the February Monitor). The agency's prior strategic plan covered the five years from 2003 to 2008. The plan is laden with policy objectives reflecting this administrative growth, and may contain a hint that the partnership between FinCEN and the IRS, specifically regarding the functions of the Detroit Computing Center, is under increased strain. Among the challenges listed to achieving a secure flow of financial information (Strategic Objective 4.1) is the following statement:

"The Financial Crimes Enforcement Network is responsible for managing the Bank Secrecy Act data filed by the regulated industries. Yet, we do not directly collect, process, store, or disseminate filed data. The Internal Revenue Service performs these functions for us under a longstanding partnership arrangement. A consequence of this activity is that we lack oversight authority over the policies and resources devoted to Bank Secrecy Act activity."

The plan goes on to refer to working within existing parameters and changing those "that can and should be altered" as being a "major, ongoing challenge." FinCEN has been content to work with the IRS (see Money Laundering, Terrorism and Financial Institutions 4.1-21), though many of the previous IRS reporting forms have been redesigned and reissued as FinCEN forms. It can be expected that the technology buildup at FinCEN will increase FinCEN's capacity and probably desire for autonomy.

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