FINCEN Email Fraud Advisory Appears To Be Inconsistent With UCC Article 4A Provisions And Wire Transfer Realities

LexisNexis (December 23, 2016, 2:54 PM EST) -- On September 6, 2016, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued Advisory FIN-2016-A003 to financial institutions, which concerns e-mail compromise fraud schemes. FinCEN intended for the Advisory “to help financial institutions guard against a growing number of e-mail fraud schemes in which criminals misappropriate funds by deceiving financial institutions and their customers into conducting wire transfers.”...