U.S. Bank Europe DAC - Enterprise Financial Crimes Compliance Team
The Risk Management and Compliance team at U.S. Bank is responsible for the company’s risk management activities across Europe, including operational risk, credit risk, fraud risk, market risk, AML, model risk, compliance and regulatory engagement.
Part of this responsibility is to ensure that U.S. Bank products and customers are not being used to facilitate these illegal activities.
The invasion of Ukraine raised many concerns about increased risks of organised crime, cross-border trafficking, and exploitation, prompting further investigation. A similar risk was identified with the Paris Olympics in 2024.
To combat this U.S. Bank Europe (USBE) undertook a plan to develop a framework of measures to proactively identify potential facilitating of trafficking events and prevent these events from occurring. These proactive measures were complementary to US Bank’s existing Financial Crimes programme.
USBE engaged the US Department of Homeland Security and, more specifically, their attaché in Paris in order to further understand the "Red Flags" and methods used by human traffickers.
USBE used the information they gained through this engagment to create bespoke transaction monitoring rules to trigger alerts for further investigation
The attaché worked closely with local law enforcement in France, USBE was able to avail of almost real-time updates on areas of focus related to potential human trafficking activity.
This work was carried out in partnership with US-based employees U.S. Bank’s parent institution who had vast amounts of experience in data analytics, law enforcement and identification of human trafficking events in the US.
US Bank’s intelligence-led monitoring and reporting of potential human trafficking activity contributes to the broader law enforcement ecosystem through financial intelligence units that collaborate across Europe via Europol and Interpol networks who, in turn, collaborate with the FBI and Immigration and Customs Enforcement (ICE), Homeland Security Investigations (HSI) as part of a ""whole-of-government"" effort involving numerous federal agencies like the Department of Justice (DOJ), Department of State and Equal Employment Opportunity Commission (EEOC) in the U.S."
Using the examples from the Ukraine conflict and Paris Olympics, U.S. Bank has reviewed and analysed over 1+ million transactions that they flagged on their systems from their red flags.
This work has enabled U.S. Bank to identify potential suspicious transactions totalling millions of euros and then to engage with the relevant government bodies and law enforcement agencies providing them with critical intelligence.