Regulatory Alerts2022-02-11 | PDF OnlyAdded
Rapid Response Program Fact Sheet
The document outlines the operational flow for the Rapid Response Program (RRP), a partnership between FinCEN, U.S. law enforcement, and foreign financial intelligence units to recover funds stolen in cyber-enabled crimes like business e-mail compromise. Activation requires a victim or their financial institution to file a complaint with law enforcement, such as the FBI’s IC3, and provide specific transactional details within 72 hours to maximize recovery success. Financial institutions are reminded of their Bank Secrecy Act obligations to file Suspicious Activity Reports (SARs) for cyber-enabled crimes, including referencing the RRP and selecting specific cyber event fields. The fact sheet also clarifies that institutions sharing information under the section 314(b) safe harbor need only have a reasonable basis to suspect money laundering or terrorist activity.