M-RCBG Associate Working Paper No. 189

Improving public-private collaboration to tackle Illicit Financial Flows on Facebook

Omayra Chuquihuara


Executive Summary

The digital era has created new opportunities for criminals to undertake financial crimes
in cyberspace. This is the case for the expansion of Illicit Financial Flows (IFFs) on social
media platforms such as Facebook. While the threat of IFFs is not new, the increasing
use of social media networks is challenging the status quo of criminal investigations led
by the United States Secret Service Office of Investigations (USSS-INV) and its partner
Law Enforcement Agencies (LEAs). Investigations have shed light to the fact that
criminals are using social media platforms to perpetrate IFFs through all three pillars of
the chain: earn, transfer, and use. Whether anonymously or not, criminals are able to
recruit targeted victims, transfer money, and flaunt purchased goods with illegal proceeds
all in one same digital space.

This report focuses on assessing the existing methods of collaboration between LEAs,
Facebook, and third-party groups to provide the USSS with policy recommendations on
improving cooperation. While the ongoing debate on regulation is important for social
media curation, this report does not focus on the legislative and regulatory stance of the
equation but rather on the implementation approach and analyzes the potential avenues
for collaboration to enhance existing protocols for criminal investigation success on
financial crimes. Given the limited research on the use of social media networks as
facilitators of IFFs, this report presents preliminary findings on Facebook specifically, with
the aim of scaling the research to other social media platforms in the long run.

In the first section, the author presents a framework to better conceptualize the complexity
of IFFs on social media platforms before presenting the case for the research on
Facebook per se. Through informational interviews with relevant stakeholders, the report
identifies the three types of processes that currently exist for collaboration as well as the
main challenges for them: bureaucratic processes, limited human and financial resources,
and ambiguous gray area for IFFs on social media platforms. For this research, the
insights from the public and private sectors were key for anecdotal cases on
investigations and final recommendations.

The policy recommendations, resulting from the proposed framework and subsequent
analysis on existing collaboration and barriers to success, focus on three stakeholders:
LEAs, Facebook, and non-governmental actors. While this report is intended for use by
the USSS-INV, the collaborative nature of its mandate resulted in the need to understand
the actions needed from each sub-group. These proposed actions in the policy
recommendations section cover initiatives on streamlining processes, improving
communications, supporting legislation, adapting to a new understanding of IFFs on
social media platforms, among others.

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