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GCN : March 2014
FinCEN launched the modernization pro- gram because its legacy, siloed systems were not up to the task of monitoring global financial activity as the volume of data and the strategic importance of financial intelligence increased in the years after the Sept. 11, 2001, attacks in the United States. BSA IT modernization was brought in on schedule and within budget, however, despite the fact that the deadline was moved up 18 months by the Office of Management and Bud- get. Major components of the project were deliv- ered in incremental releases, which included: • Electronic filing. Paper-based reports on transactions from financial institutions were replaced with filing through the BSA Electronic Filing System. Ninety-three percent of reports now are captured electronically. • System of records. Eleven years of FinCEN data, about 850 million records held by the IRS, were transitioned to FinCEN s new system in the NIEM format by January 2012. • Advanced analytics. Three releases of a new analytics tool suite based on the SAS Fraud Framework were implemented. • Data collection. Four new data collection reports on suspicious activity, current transac- tions, money services, business registration and designations of exempted persons were imple- mented. • New query system. FinCEN Query was in- troduced in September 2012, replacing the Web- based Currency and Banking Retrieval System and allowing advanced searches across more than a decade of data. Since FinCEN Query went live, 1.1 million queries have been made through the system by more than 1,600 users, said Deloitte s Young. "If it wasn t useful and relevant, there wouldn t have been that much usage." • BY WILLIAM JACKSON The Treasury Department s Financial Crimes Enforcement Network (FinCEN) is responsible for enforcing the Bank Secrecy Act, a job that in- volves collecting, searching and analyzing finan- cial transaction data for evidence of wrongdoing. As the urgency of this mission grew, especially over the last decade, FinCEN faced a host of big data challenges with a legacy of small data tech- nology. Some of these hurdles were common to the government IT enterprise: Data (provided by ex- ternal financial institutions) was inconsistent in quality and format, it was broken into small data- sets, search and analysis was limited and online access for federal, state and local agencies using the data was not adequately secured. The BSA IT Modernization program set about updating the systems in 2008, transferring 11 years of data totaling 400 gigabytes from the IRS to a new FinCEN system of records. The system adhered to the National Information Exchange Model (NIEM) format, enabling electronic filing of new records by financial institutions, creating an online portal for access and developing a Web- based query and analytical application. Now records are electronically filed, centrally managed and stored in a standardized format, and a new online portal and Web-based query engine allows secure access and analysis by more than 10,000 authorized users across more than 400 federal, state and local agencies. "This was a complex and challenging imple- mentation," said Tim Young, a principal at De- loitte Consulting, the prime integrator for the modernization program. "To pull it off required developing business requirements as well as ad- dressing technical issues. We needed expertise across a number of technical and nontechnical domains." Treasury tunes up anti-fraud network The Financial Crimes Enforcement Network was retooled to handle the growing complexity of financial intelligence PROJECT AT A GLANCE PROJECT: Bank Secrecy Act IT Modernization OFFICE: Treasury Department Financial Crimes Enforcement Network (FinCEN) TIME TO IMPLEMENTATION: Six years from the initial planning; the O ce of Management and Budget moved the deadline up by 18 months during the project. BEFORE: Millions of financial transaction records were maintained in siloed data sets with no standard format. Access to and analysis of the records by law enforcement, intelligence and regulatory agencies to detect financial fraud was time consuming, and securing the data was di cult. AFTER: Records are electronically filed, centrally managed and stored in a standardized format, and a new online portal and Web-based query engine allows secure access and e cient analysis by more than 10,000 authorized users across more than 400 federal, state and local agencies. 16 GCN MARCH 2014 • GCN.COM