In 2003, the US government changed the fraud fight forever. A seemingly small addition to a broader act required financial institutions to fight and protect their customers from identity theft, leading to the establishment of the Identity Theft Officer. I must admit, I didn’t think much of it at the time, as I was working for a top global financial institution that was already laser-focused on stemming the fraud losses connected to the increase in identity theft. But I now recognize it for what it was and its profound impact on the industry.
Human Crime—human trafficking, child exploitation, scams, and elder exploitation—is increasing at an alarming rate. Criminal organizations have diversified into all types of human exploitation, fueled by greed and propelled by technology.
Most of these Human Crimes do not present a financial loss or danger directly to a financial institution. However, they threaten to destabilize the global financial system through the facilitation of criminal activity at a scale we have never seen before. The most horrific example is enslaved people in global scam centers to accelerate the proliferation of scams and the distrust that all of us have in operating our everyday life. From unsolicited texts and calls to AI-generated child s** abuse material (CSAM), s**tortion, scam center labor trafficking, and pig butchering, the scope and scale of criminal exploitation is expanding rapidly.
By some accounts, there are almost 5000 banks in the United States and organizations that could be classified as financial institutions, delivering essential services to the global economy and propelling everyday business. Yet, based on what I have witnessed, regulations have not kept up with providing a credible reason for financial institutions to directly involve themselves or make meaningful investments to advance the Human Crime fight. An increase in regulations to accelerate the financial industry into action is an important step. However, the risk of well-meaning but misguided or short shelf-life laws is that we create a burden on the financial industry while we are still working to uncover the best path forward to protect our communities.We need to take incremental and measured steps to spur and support innovation and provide enough executive-level visibility to justify the needed attention.
Enter the Human Crime Officer.
At a recent Knoble leadership offsite meeting on a mountain south of Chattanooga, a group of seasoned Financial and Law Enforcement leaders gathered to discuss how to advance our ‘noble’mission and strategically propel the industry to protect the innocent. A simple idea caught fire—and I have latched on—a first step to getting to where we need to be.
A Human Crime Officer is a simple designation at every bank and financial institution, to name an equipped leader to build a Human Crime Protection program that cares for the human being behind our transactions. I believe that a true Return on Investment (ROI) will be identified beyond theory once we uncover the true impact of human exploitation on our global business models. In the meantime, this designation would ensure every financial institution has someone advocating for consumer protection internally and tracking its impact. Similar to the Identity Theft Officer, the Human Crime Officer would:
1) establish a Human Crime policy within a financial institution,
2) establish a program to understand a financial institution’s inherent Human Crime risks and document the organizational efforts to manage each risk,
3) align organizational efforts to track occurrences of Human Crimes, and
4) annually report to the board of every Financial Institution on the program health and risks.
This is not the long-term solution to solve Human Crime, but the introduction of this designation will undoubtedly have a significant impact on advancing advocacy, defenses, innovation, education, and protection of the most vulnerable.
This simple move of a Human Crime Officer designation would be the first step to significantly advance the fight against human exploitation, just like the Identity Theft Officer advanced identity theft protection. With a low level of investment from the financial community, this would reinforce efforts to innovate and solve the existing roadblocks and hesitations being expressed inside the financial community to develop anti-human exploitation programs.
(I want to state that the financial industry is not the only sector that needs to be involved at an increasing level to protect our society from Human Crimes. But it is the sector that I am from, a sector that is made up of the best and brightest, a sector that has proven the ability to drive innovation and rise to manage all types of risks. This is also the primary ecosystem that criminals are leveraging to monetize the exploitation of people. So why not start with the financial sector? I am convinced that we can meet this challenge.)
How can The Knoble assist? The Knoble is a network of individuals committed to fighting Human Crimes from financial services around the globe. The Knoble has established a community for trend and intelligence sharing across all kinds of Human Crime. Additionally, The Knoble provides training and collaboration that Human Crime Officers could take to become ‘credentialed’ in this emerging risk type. The term “Human Crime” was coined by The Knoble in 2019 to highlight the human toll behind financial crime risks.
Huge ‘thank you’ to Contributors for the assistance in writing this article and The Knoble Leadership for the great work that lead up to it. Including: Richard Stocks – CAMS , Jonathan Bell , Robert (Bob) Shiflet , Rose McQuitty, David Worland, Donna Turner