Falciglia: Treasury Needs To Extend Suspicious Activity Reporting Requirements to Local Governments

STATEMENT BY ROCKLAND COUNTY LEGISLATOR CHARLES FALCIGLIA
“I have requested that the United States Department of the Treasury conduct a study to extend suspicious activity reporting requirements to include local governments. Over the last decade Anti-Money Laundering Programs have been expanded from Banks to include the Gaming Industry (Casinos), Insurance Industry, Precious Metals and Jewelry Dealers, Mortgage Companies/Brokers, the Securities and Futures Industry and Money Service Businesses.
“I have outlined in my letter why I believe this can be another avenue in the pursuit of corruption and white-collar crime, simultaneously forcing elected officials to be penalized for looking the other way. It would provide an independent conduit, such as an Inspector General, to report possible criminal behavior and act as a check and balance on other government agencies.
“The most important aspect of this position would be independence, protected to a great extent by federal oversight. By making this a federal regulation, local governments would be required to make reports with civil and criminal penalties attached for being non-compliant or willfully blind. It would also allow the general public a secure source to have any suspicions they wish to report forwarded directly to a non-local agency for review.
“Suspicious activity reporting can result in reviews by the IRS Civil and Criminal Investigation Divisions, the FBI, Homeland Security, Immigration and Customs, the ATF, the United States Postal Service and any other agency deemed appropriate.
“While unmasking LLCs is a step in the right direction, the source of funds is always the main concern; and not just the initial source, but the secondary source and beyond, the true beneficial owners. This area is fast becoming a concern of our Federal Government.”

County Legislator Charles Falciglia is a certified Anti‐Money Laundering Specialist who has enjoyed a 37‐year career as a banking professional, currently holding the position of Bank Secrecy Act Officer for the United States branches of an international bank.

He also is an award‐winning economic crime writer for ACAMS Today, a magazine for professionals in the anti‐money laundering field.