FinCEN issues alert on deepfakes, UK introduces guidance on new fraud offense, and the importance of real-time PEP data updates

FinCEN has issued an alert on fraud schemes involving deepfakes: synthetic, realistic media created using generative AI. The alert advises on common typologies, such as the use of fake documents, photos, and videos to bypass identification and verification checks. Criminals alter existing media or create synthetic identities for schemes such as APP fraud, phishing scams, and funnel accounts. Deepfake fraud red flags include: 

• Customer photos inconsistent with information such as date of birth. 
• Customers using third-party webcam plugins or changing communication methods due to technological glitches during live verification checks. 
• Customer geographic or device data inconsistent with their ID. 

Firms should include the reference FIN-2024-DEEPFAKEFRAUD when filing SARs. 

The UK government has provided guidance on its new ‘failure to prevent fraud’ offense. This was introduced in the Economic Crime and Corporate Transparency Act 2023 but is not due to come into effect until September 1, 2025. The guidance clarifies which organizations the offense applies to, with criteria around turnover, assets, and headcount. It states they do not need to be the main beneficiary of fraud or receive any actual benefit to be liable. Firms should particularly note the section on reasonable fraud prevention procedures, including risk assessments, training, and monitoring.

In a year when more than half of the world’s population will have headed to the polls, it has never been more critical to have comprehensive global PEP data delivered in near real-time. I want to take a moment to highlight the work our data teams are doing to serve customers in this area.

At 05:34 EST on November 5, the US presidential election was called for Donald Trump – less than 3 hours later, ComplyAdvantage’s data was updated with his active start date. 30 new Senate members were elected by the next business day, with our data updated at 10:17 EST, and within 48 hours of the president-elect declaration, 411 individuals were confirmed as members of the House of Representatives. ComplyAdvantage customers could access fresh data reflecting this before working hours began on November 6. Take a look at our new PEP information hub to view our latest updates and learn everything you need to know about building an effective PEP screening program. 

Until next week,

Andrew Davies, Global Head of Regulatory Affairs.