With online sexual exploitation of children rising, early detection and prevention of suspicious activities is essential. Monitoring and tracking suspicious financial behaviour might provide insight into sources of child exploitation, so banks and financial institutions (“FIs”) have an opportunity to form compliance programs, which address this directly. In late 2020, FTI Consulting’s investigations and financial crime compliance experts were engaged by a top-tier law firm on behalf of ICMEC to develop a toolkit on how banks and FIs might structure their compliance programs to detect and prevent suspicious activities.
The toolkit and high-level typology-driven data analytics framework that was developed enables banks and FIs to identify and report transactional activity indicative of child exploitation.
With more than 70 hours dedicated to the pro bono project, FTI Consulting helped develop risk management guidance and educational tools for law firms, FIs and ICMEC to monitor suspicious financial activity that might lead to child exploitation.
FTI Consulting experts provided a “teach-in” to both ICMEC and the law firm project team, covering the mechanics of payment flows and transaction monitoring and reporting by FIs, differences between monitoring by “core” retail banks and other payment intermediaries, difficulties that may arise as a result, and areas of weakness for FIs in identifying and reporting issues and in interacting with regulators and law enforcement agencies.
Our team assisted in developing a process to better understand how select FIs identify transactions that are potentially related to the online sexual exploitation of children.
Our team participated in outreach to FIs to understand their risk management practices around monitoring child exploitation in their respective institutions.
FTI Consulting experts helped develop materials for anti-money laundering (“AML”), investigations and AML data analytics teams.
The FTI Consulting team has entered Phase II of the engagement, where they are playing a key role in the launch of a toolkit designed to combat the misuse of the financial system for online sexual exploitation of children.
In our effort to counter the scourge of commercial child sexual exploitation, ICMEC benefited greatly from the knowledge and expertise of the FTI Consulting team. In particular, the team’s experienced approach to risk and compliance added substantive content and nuance to the development of the Child Protection 101 – A Toolkit for the Financial Industry. We could not have expected more from a partner and are truly grateful.
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