Does FinCrime Participants information contribution conflict with the Gramm-Leach-Bliley Act (GLBA)?
GLBA generally requires protection of the security and confidentiality of customer records and information. However, GLBA contains certain exceptions, including 502(e)(3) which provides as follows: “GLBA shall not prohibit the disclosure of nonpublic personal information to protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liability.” Since FinCrime members will provide information that is for the purpose of protecting or preventing actual or potential fraud, unauthorized transactions, claims, or other liability, such sharing of information is specifically permitted under GLBA.
