Detecting and Reporting the Illicit Financial Flows Tied to...

Organized Theft Groups (OTG) and Organized Retail Crime (ORC) .  A Comprehensive Educational Guide for Law Enforcement and Financial Crime Investigators  

By Lauren Kohr and Tiffany Polyak,

Organized retail crime (ORC) remains at the forefront of most major news channels across the United States. High-profile “smash-n-grab” robberies, and nationwide cases involving major retailers in Chicago, Los Angeles, and San Francisco, garner the headlines. Recent hearings by the United States Congress, that discuss and debate proposed legislation, target the ability of criminal organizations to resell stolen goods online with relative anonymity.1 ORC is a low-risk, high-reward business line for transnational criminal organizations’ portfolios that presents a significant financial and public safety risk. While retailers and law enforcement partner to investigate ORC cases and provide education on the misconceptions and misunderstandings, it is clear there is a missing link in these partnerships, and that link is financial institutions. Criminal organizations need to launder the nearly 70 billion US dollars of illicit proceeds gained from ORC activities annually. These organizations are looking to launder their billions through the formal financial sector, unregulated payment processors, and online marketplaces. 1. The Brand Protection Professional, Professional Pointer: What Is ORC And Is It Related To IPRC? To combat ORC and take down organized theft groups (OTGs) more effectively, first, financial institutions must be brought into the awareness and education triangle. Second, public-private partnerships and information-sharing channels between retailers, law enforcement, and financial institutions need to be created. Third, as law enforcement and retailers prioritize investigations involving ORC, financial institutions should look to reasonably enhance their anti-money laundering (AML) and counter-terrorist financing (CTF) programs to detect and report illicit proceeds stemming from these crimes. Financial institutions should ensure proper controls are in place to detect and report illicit activities tied to or involving ORC. While not specifically addressed in the National AML/CFT Priorities issued by the Financial Crimes Enforcement Network (FinCEN) on June 20, 2021, it should be addressed that ORC has been tied to many of the priorities issued and other heinous crimes, as reflected in this guide.  

ACAMS and Homeland Security Investigations, 53p.