FinCEN Advisory on Elder Financial Exploitation

This past Wednesday, June 15 was World Elder Abuse Awareness Day. FinCEN has issued Advisory FIN-2022-A002 on Elder Financial Exploitation (EFE), which involves the illegal or improper use of an older adult’s funds, property, or assets and is often perpetrated either through theft or scams. The advisory highlights new EFE typologies and red flags since FinCEN issued its first advisory on the issue in 2011.

FinCEN’s EFE advisory highlights behavioral and financial red flags to aid financial institutions with identifying, preventing, and reporting suspected EFE. In line with the risk-based approach to compliance with the Bank Secrecy Act, financial institutions should perform additional due diligence where appropriate and remain alert to any suspicious activity that could indicate that their customers are perpetrators, facilitators, or victims of EFE.

In addition to filing a SAR, FinCEN recommends that financial institutions refer their older customers who may be victims of EFE to the Department of Justice’s National Elder Fraud Hotline at 833-FRAUD-11 or 833-372-8311 for assistance with reporting suspected fraud to the appropriate government agencies. For educational resources on EFE and scams targeting older adults, see the CFPB’s Office for Older Americans.

FinCEN's advisory notes that financial institutions filing an EFE-related SAR should reference the advisory by including "EFE FIN-2022-A002" on SAR field 2 and mark the check box for elder financial exploitation.