TRAC Data Policy of 8_28_2023 - Laserfiche WebLink

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TRANSACTION RECORD ANALYSIS CENTER DATA POLICY Effective: 8/28/23 1. Background Transaction Record Analysis Center ("TRAC") is currently a 501(c)(3) non-profit corporation, but was initially established in 2014 by the Arizona Attorney General's Office through a settlement agreement entered between the Arizona Attorney General's Office and Western Union. TRAC has since developed into a successful collaboration among state, local and federal law enforcement agencies. TRAC aims to combat money laundering activities and enhance and better coordinate investigations and prosecutions of money laundering offenses by providing analytical and data -related assistance to federal, state, and local law enforcement agencies. 2. Preface TRAC fulfills its objective by managing a database of money transmitter data ("Data"), which is shared with law enforcement agencies, and by providing expertise, meaningful data analysis, training, and organizational collaboration with its law enforcement and money transmitter industry partners. TRAC empowers law _enforcement with specificreactive,__investigation-driven analysis_ and proactive risk, pattern, and target analysis to achieve its objective. The Data is highly relevant to law enforcement efforts to identify individuals engaged in money laundering activities and better understand the channels, amounts, and vulnerabilities of the flow of illicit money from source/consolidation areas. This Policy sets forth the terms federal, state, and local agencies and their employees, contractors, or other personnel ("Users") must comply with to gain access to TRAC. 3. Scope This policy applies to all TRAC Users. TRAC will be available only to authorized personnel from agencies that have agreed to a TRAC agency MOU and have a need -to -know -the Data to perform their job duties and responsibilities in furtherance of anti -money laundering (AML) Purposes. All Users shall adhere to the current version of this Policy. 4. TRAC Integration and Data Security TRAC Data is secured by its agent, a cybersecurity and data management company, and operated under all applicable laws pertaining to the authorized collection, proper use, retention, and secure dissemination of sensitive law enforcement information, including adherence to all applicable privacy, confidentiality, information security, and civil liberties statutes and regulations. Users of this Data shall (i) maintain appropriate administrative, technical, and physical safeguards and other security measures designed to ensure the security and confidentiality of the Data; (ii) protect against any anticipated threats or hazards to the security and integrity of the Data; and (iii) protect against any actual or suspected unauthorized or inappropriate processing, loss, use, disclosure, or acquisition of or access to the Data, whether by agency personnel or otherwise (hereinafter "Data Security Incident"). User agencies shall notify TRAC within 24 hours upon revoking access to any User, imposing sanctions on any User in connection with the Data, or any Data Security Incident. TRAC will condition query access on the entry of individual User agreements and on a requirement that each query begin with the completion of computer access screens providing User information, case identification, purpose, etc.