Scott Anchin: Fight Fraud By Partnering with Law Enforcement

Law enforcement partnership has been a consistent theme of this column. It shaped the network of trust I described in the elder fraud context, and it drove the mail theft campaign we ran with the U.S. Postal Inspection Service. On July 1, ICBA and the International Association of Financial Crimes Investigators released “Community Banks and Law Enforcement: A Partnership Framework for Mutual Success.” This framework gives the relationship a defined operating discipline, with each side supporting the other.

The document’s distinguishing feature is its symmetry. Most guidance enumerates what banks should provide. This one also describes the support investigators can provide banks, including status updates, feedback on filings, a named liaison and confidential handling. That balance reflects its authorship: A small joint working group drawn from IAFCI and our Fraud and Scams Task Force developed the text.

The framework’s central operational claim is that outcomes are decided early. Most successful investigations and recoveries take shape within the first 48 to 72 hours. Therefore, the relationship, point of contact and shared vocabulary must exist before the incident occurs. Check fraud alone generates more than 1,800 suspicious activity reports daily, and in 2025 set records. At that scale, early preparation protects both balance sheet and customer trust.

One form of preparation became easier this summer. Section 314(b) of the USA PATRIOT Act allows registered financial institutions to share information about suspected money laundering or terrorist activity. The statute provides a safe harbor from liability when program conditions are met. FinCEN’s June 12 revision of its guidance removes the hesitation that kept it underused. Suspected fraud is within its scope, sharing may occur in real time and monitoring alerts may move between registered institutions. It remains guidance rather than statute, so counsel should stay involved. Even so, concerns that kept programs dormant now have written answers.

The postal campaign supplies the proof of concept, since co-developed prevention materials reached hundreds of community banks within months. Community banks and law enforcement can, do and should work together at national scale and locally.

Here are four steps to put the framework into practice:

1. Designate a fraud contact with after-hours availability and give local agencies their contact information before an incident requires it.
2. Register for Section 314(b) and establish the internal procedures that turn registration into use.
3. Bring the framework to the nearest financial crimes task force. Where none exists, convene one with several banks and two agencies meeting quarterly.
4. Offer local investigators a working session on bank mechanics, covering Regulation CC holds, warranty claims and why a written request on letterhead accelerates production.

Download the guide here. If your bank puts it into practice, please let me know at checkfraud@icba.org.