WorkflowFraud Prevention & Investigations

Elder Financial Exploitation Detection

Elder financial exploitation seen in the people around the money, with every hold, report and referral decided by a person

Every concern about an older member acted on the same day, with each step on the record.

See one case, screen by screen ↓
demo7signalsbehind the sample member's concern, each cited to its record, laid out six minutes after the teller's report
demo0mentionsof the SAR referral on any branch, member, joint owner or trusted-contact view the Safeguards agent checked
target1hourat most from a branch report to the first protective step, while the member is still there
target5of 5policy steps documented for every case, with who decided, why and on which evidence
In short

What is Elder Financial Exploitation Detection?

Elder Financial Exploitation Detection is software for credit union and bank fraud and BSA teams that spots elder financial exploitation in the people around an older member's money, then prepares each protective step for a person to decide. Seven agents show who is new and when they appeared, compare the money moves with the member's own pattern, lay out the steps of the institution's policy with their clocks, and draft the guides, the delay notice, the APS report and the SAR referral. A delay and an APS report each need a second person.

AI use cases in banking: a buyer's guide to agentic AI for bank and credit union operations →

Updated

The problem

Why elder financial exploitation rarely looks like fraud

Elder financial exploitation rarely arrives as one suspicious transaction. A new "friend" is added to the account at one branch, the phone number on file changes through the contact center, online banking is opened from a new phone, a payee appears, gift cards follow, and then the large request comes at a teller window with the new person standing beside the member. Each change lands in a different system, and none of them alone breaks a fraud rule, because most of it looks authorized: in FinCEN's one-year study, about 80% of reports involved scams in which the older adult often moves the money themselves.

The response is improvised too. Whether a teller delays, whom to call, what may be told to a niece, which state deadline applies and whether the reporting employee is trained under the Senior Safe Act all live in a policy document and in people's memory. A SAR referral typed into a comment field shows up on a branch screen; a delay letter addressed to both owners tips off the suspect. Elder Financial Exploitation Detection puts the member at the center of the people around their money, and seven agents prepare each step of the credit union's policy for a person to decide.

typical$27billionof suspicious activity in 155,415 elder financial exploitation reports to FinCEN in one year
typical80%of those reports involved scams by strangers; about 20% theft by someone the older adult trusted
typical$28.3billiona year in losses to older adults, a published estimate cited in the 2024 interagency statement
Where a concern's working hours go, from the teller's report to the last sign-offestimated
By hand11.5 hours
With the solution1.5 hours
  • Gathering owners, trusted contacts, powers of attorney, payees and devices from five systems3 → 0.1 h
  • Comparing the money moves with the member's own pattern2 → 0.1 h
  • Working out the policy step and the state hold law's business-day clocks1 → 0.1 h
  • Writing the conversation guide, the trusted-contact call guide and the delay notice2 → 0.3 h
  • Drafting the APS report and checking the reporter's Senior Safe Act training2 → 0.4 h
  • Second-person sign-offs and the SAR referral1.5 → 0.5 h

Estimated split of the working hours one concern about an older member takes, by hand and with the agents. Our estimate, kept modest; in the working solution the sample case ran from the teller's report at 9:52 a.m. to the SAR referral at 11:05 a.m.

How it works

How a concern about an older member moves

Seven agents watch, map, draft and check; staff decide every step and a second person approves.

What comes in
Signals in5 systems · teller platform, core, digital banking, card processor, monitoring
Agents at work
Pattern agenther own 12-month pattern
Circle agentwho is new, and when
Then
Policy agentsteps and business-day clocks
Then
Drafting agentguides, notice, APS report
Safeguards agentconsent, training, SAR checks
Then
Follow-up and Reporting agentsdelay ends, APS replies, exams
A person decides
Specialist and approversbranch manager approves delays; BSA Officer approves reports
What comes out
The member's circle
Delay with notice
APS report and SAR referral
One case, step by step

One elder financial exploitation case, from the teller window to the APS report

Eleanor Marsh, 81, has been a member of Norrell Federal Credit Union since 1974. On a Thursday morning she comes to the Halvern branch to cash out a certificate. Here is what happens next, screen by screen, in the working solution.

  1. 019:52 a.m.

    A teller reports a concern while the member waits

    Jamal Whitcombe · Member Services Representative

    With Curtis Vane beside her, Eleanor asks to close her 24-month certificate early: $42,000, with a $604 penalty, by official check payable to Curtis. Jamal presses Report a concern at his station. The alert goes to the top of the specialist's list.

    "The friend answered every question. She was not sure what the money was for."

  2. 02Six minutes later

    The people around her money, in one circle

    Circle, Pattern and Policy agents

    By 9:58 a.m. the agents have built Eleanor's circle and opened case EFE-26-0287 with a concern of 0.91. Her niece Ruth Marsh-Okafor has been her trusted contact for 3 years, and her caregiver Lorna Pike has held a power of attorney for 18 months with steady spending. Curtis Vane, a joint owner, and Ridgeline Restoration LLC, a payee, are new this month.

    "A friend added as joint owner 19 days ago now has Eleanor's phone number and online banking, and today she is asking to cash out a $42,000 certificate to him."

  3. 03One click

    When he appeared, and what he did

    Teresa Lindqvist · Elder Financial Protection Specialist

    Teresa opens Curtis Vane's record. He was added as joint owner at the Westbrook branch on Saturday, October 3; the phone of record changed on October 5; online banking started from a new Android phone on October 6; and that phone added the payee Ridgeline Restoration LLC on October 9. Each line cites the system it came from.

    Links people only on two or more identifiers, never on a name alone.

  4. 04Her own pattern

    Seven signals against her usual spending, and what did not change

    Pattern agent

    Eleanor's outflows ran about $2,600 to $2,720 a month from April to September; October reached $7,400 by the 22nd, with $2,400 to Ridgeline Restoration LLC and $3,100 in gift cards. A fairness check shows what did not change: Lorna Pike's spending has stayed at $590 to $690 a month for 18 months, so a long-standing caregiver is not treated as a suspect.

  5. 0510:06 a.m.

    A private conversation, her purpose in her own words

    Owen Barrow · Branch Manager

    The Drafting agent's guide gives Owen six plain questions and a reminder never to say victim, scam or confused. He records Eleanor's answers: the money is for a roof Curtis is arranging, and she has seen no contract. She agrees the credit union may call Ruth and tell her about Curtis and the roof.

    "Yes, you can call Ruth and tell her about Curtis and the roof."

  6. 0610:24 a.m.

    The trusted-contact call, within what she agreed to

    Teresa Lindqvist

    The call guide uses only what Eleanor's 2023 consent and today's conversation allow, and the Safeguards agent passes it 3 of 3: within consent, no amounts or accounts, no report named. Ruth has never heard of Curtis, and the roof was replaced in 2022. She will come to the branch with Eleanor on Friday at 10:00 a.m.

    "I have never heard of a Curtis. The roof was replaced in 2022; I paid half."

  7. 0710:31 a.m.

    A disbursement delay, approved by a second person

    Teresa Lindqvist and Owen Barrow

    The Policy agent proposes the delay and computes the state hold law's clocks: 5 business days, in force to Thursday, October 29, with the notice due Monday, October 26 and the review result due Monday, November 2. Teresa sends it and Owen approves it as the second person. The notice goes to Eleanor; Curtis is excluded as a party reasonably believed to be involved.

  8. 0811:02 a.m.

    The adult protective services report, approved before it is filed

    Priya Castellane · BSA Officer

    The Drafting agent fills every section of the state APS report from the case, each value cited: $5,500 paid out, $42,000 delayed. The Safeguards agent confirms Senior Safe Act training for Teresa (February 11, 2026) and for Jamal (January 20, 2026), and that no SAR is mentioned. Priya approves, and Teresa uploads the report to the state portal and records its reference.

  9. 0911:05 a.m.

    A confidential SAR referral, with FinCEN's key term

    Teresa Lindqvist

    The referral to the BSA team carries the key term EFE FIN-2022-A002 for field 38(d), names Curtis Vane and Ridgeline Restoration LLC, and sets the filing date of Saturday, November 21. The Safeguards agent lists every place it must never appear, each with 0 mentions: the teller platform, the branch view, Eleanor's online banking and statements, the delay notice, Ruth's call guide, the APS report and anything Curtis can see as joint owner.

  10. 10The same morning

    The same phone, on a second member's account

    Circle agent

    Curtis Vane's phone number, 555-0163, has been Walter Brisbane's phone of record since September 10, and the same Android device signed in to both members' online banking. Walter, 84, has withdrawn $9,800 in cash in four Westbrook visits since. The agent proposes a linked case; Teresa opens EFE-26-0291, and neither member nor either branch is told about the link.

Who it’s for

Built for everyone who protects an older member's money.

The same case, seen by the four people who carry it: what their day looked like, and what it looks like now.

TL
Teresa LindqvistElder Financial Protection Specialist · owns 21 of the 34 open cases
Elder Financial Protection Specialist
Before
Pieces the picture together from five systems after a branch calls. "By the time I see the whole picture, the check has cleared."
Now
Opens the member's circle with who is new already found and cited, the policy steps laid out with their clocks, and each guide, notice and report drafted for her to check.
OB
Owen BarrowBranch Manager · Halvern branch, 9 people
Branch Manager
Before
Talks with a worried member with nothing but instinct. "My tellers see it first. They need to know what to do in the next ten minutes."
Now
Has six plain questions to ask, records the member's answers in her words, and approves a delay he did not propose.
PC
Priya CastellaneBSA Officer · approves APS reports, longer delays and SAR referrals
BSA Officer
Before
Signs off reports assembled by hand. "Every report we make to the state has to be one I can defend to an examiner."
Now
Sees each value cited, the reporter's training confirmed and the SAR kept off every member and branch view before she approves.
GA
Gloria AsanteInternal auditor · prepares the NCUA exam, changes nothing
Internal auditor
Before
Reassembles each case from email, the case tool and the training system. "Show me who decided, on what evidence, and that they were trained."
Now
Builds an export pack for the examiner with the timeline, every sign-off, the training records and the agent versions.
Built on the engine

7 agents. Each with one job, and hard limits.

Seven agents watch, map, draft and check; staff decide every step and a second person approves.

Pattern agent

Compares an older member's money moves with their own 12-month pattern and flags changes: new payees, gift cards, early certificate closures, cash and first wires, with FinCEN's red flags as its reference.

  • Never holds, blocks or contacts anyone
  • Below a concern of 0.70 it only watches
Circle agent

Builds the circle of people around a member's money (owners, trusted contacts, agents under a power of attorney, payees, devices, phone and address changes) and links members who share them.

  • Never links members on a name alone; at least two identifiers
  • Never changes a member record
Policy agent

Maps the facts to the interagency statement and the credit union's policy EFE-3, and computes the state hold law's business-day clocks and the 30-day SAR clock.

  • Proposes steps; never sets a delay
Drafting agent

Drafts the conversation guide, the trusted-contact call guide, the delay notice, the APS report and the SAR referral narrative in dignity-first words, every value cited.

  • Never sends or files
  • Never calls a member a victim or confused
Safeguards agent

Checks each draft against the person who will read it (consent scope, a suspected party, SAR confidentiality) and the reporting employee's Senior Safe Act training.

  • Blocks a draft that breaks a rule
  • A SAR check cannot be overridden
Follow-up agent

Sets and sends reminders: a delay ending, an APS response due, and the 90-day watch after a case closes.

  • Never releases or extends a delay
Reporting agent

Drafts the quarterly program report for the risk committee and builds examiner export packs with training evidence.

  • Counts only in board reports; no member names
  • The BSA Officer approves the report
Specialist, branch manager, BSA Officer

Decide, approve and file. The agents propose; a named person decides.

Ask in plain words

Ask about the member, the people or the rules

The specialist can ask about anyone in the circle, any step or any rule. Every answer cites the records it came from.

Why 0.91 and not lower?

Seven signals line up behind one new person. Curtis Vane was added on October 3; two days later the phone changed, then online banking, a payee and first-ever gift cards. Today the certificate check is payable to him, and the teller saw him answer for her. Any one alone would score under 0.60.

Is Lorna Pike part of this?

Nothing points to her. Lorna has used the power of attorney for 18 months at $590 to $690 a month, with the same payees and no cash; October is no different. She is not on the certificate request and has no link to the new phone or payee.

What does the state hold law let us do?

We may delay a disbursement when we reasonably believe it may result in exploitation, give notice within 2 business days to Eleanor and anyone authorized who is not suspected, and keep it up to 15 business days unless a court extends it. Our policy has the branch manager approve up to 5, the BSA Officer longer.

Who else has Curtis Vane's phone number?

One other member: Walter Brisbane, 84, at Westbrook. His phone of record has been 555-0163 since September 10, and the same Android device signed in to his digital banking. He has withdrawn $9,800 in cash since. I propose a linked case; you decide.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

The member at the center of the people around her moneyEleanor Marsh, 81, is at the Halvern branch asking to cash out a $42,000 certificate. Her trusted contact and her caregiver with a power of attorney have been on file for years; a joint owner added 19 days ago and a payee added 13 days ago are new. Above the circle, the agents' concern in one sentence (0.91) with its sources; below, when each person appeared against the money; to the right, the five policy steps with owners and deadlines.
Today's elder financial exploitation alerts, each with the member's circleThe specialist's morning: the agents' briefing in three sentences, then 9 new alerts on members 65 or older since 5:00 p.m. yesterday. Each row shows a small circle of the people around the member, the concern in one sentence, the red flags and their source, and the proposed next step with its clock.
Elder financial exploitation red flags against her own patternThe Pattern agent compares Eleanor's outflows with her own 12 months and lists the 7 signals behind the concern, each with its record. October reached $7,400 by the 22nd against about $2,650 a month. What did not change is shown too: her caregiver's steady spending and her $3,480 monthly deposits.
One person's record: when he appeared and what he didThe new joint owner, Curtis Vane, with each change since he was added, cited to the system it came from: the phone of record changed, online banking from a new Android phone, a new payee, and today's certificate check payable to him. The same phone and device are on another older member's account.
A conversation guide that records her purpose in her own wordsThe branch manager talks with the member privately using six plain questions. Her answers, her stated purpose and her consent to call her trusted contact are recorded with the time and his name, and the agent lists the red flags heard: a third party answered for her, no contract for a large payment, urgency.
The trusted contact person call, within what she agreed toThe call guide uses only what the member's 2023 consent and today's conversation allow, and the Safeguards agent checks it: within consent, no amounts or accounts, no report named. The specialist logs what the trusted contact said.
A disbursement delay under the state hold law, approved by a second person$42,000 delayed 5 business days, to Thursday, October 29, approved at 10:31 a.m. by the branch manager. The notice is due Monday, October 26 and the review result Monday, November 2. The notice goes to the member; the joint owner is excluded as a party reasonably believed to be involved.
The adult protective services report, approved by the BSA OfficerEvery section of the state APS report drafted from the case with each value cited. Before it goes, the Safeguards agent confirms the Senior Safe Act training of the employee who files and the one who first reported, and that no SAR is mentioned. The BSA Officer approves at 11:02 a.m.
Elder financial exploitation SAR reporting that never tips offThe referral carries FinCEN's key term EFE FIN-2022-A002, a cited narrative and the filing date of November 21. The Safeguards agent lists every view and draft where it never appears, each with 0 mentions, from the branch teller platform to anything the joint owner can see.
A second member found through the same phone and devicePhone 555-0163 has been Walter Brisbane's phone of record since September 10 and Eleanor's since October 5, and one Android device signed in to both members' online banking. The agent proposes a linked case; a person opens it, and neither member nor either branch is told.
Every open case, with its next step, owner and clock34 open cases with filters for due today, overdue, delays ending and APS steps, search, and bulk actions to assign, remind or export. Two delays end in the next days, each to be released or extended; a missed clock goes to the BSA Officer.
Senior Safe Act training, checked before every report598 of 612 staff are current, 9 are due in 30 days and 5 are overdue, and every employee reporting on an open case is trained. When the learning management system timed out at 9:55 a.m., the screen said so and the retry answered at 9:56.
An audit trail and an export pack for the NCUA examinerEvery action by people and agents on a read-only trail with who, what, when, why and the evidence. The pack for case EFE-26-0287 holds the timeline, the 7 signals, the conversation and the call, the delay, the APS report and the SAR referral with every sign-off, training records and agent versions: 46 pages, checksum recorded.
Governance

Built for elder financial exploitation risk: cited, signed by two people, never tipped off.

Six roles, separated by dutySpecialists investigate and propose; branch managers approve delays up to 5 business days; the BSA Officer approves APS reports and longer delays and accepts SAR referrals; tellers report a concern and see only their receipts and the steps they own; the auditor reads and exports; the administrator runs settings and never opens a case. No one approves a step they proposed.
A second person on every step that mattersA disbursement delay, an account restriction and an APS report each need a second person, and a delay over 5 business days goes to the BSA Officer. Agents never hold, release, send, file or change a member record.
SAR confidentiality, lockedA SAR referral and its existence never appear on a member, joint owner, trusted-contact or branch view. The setting is locked, and the Safeguards agent checks every draft for it; a person cannot override that check.
Senior Safe Act training checked before a reportTraining records are read from the learning management system, and the training of each employee who reports is confirmed before an APS report is approved. An untrained reporter is flagged and routed.
Versioned agents, thresholds and reason codesEvery agent is versioned, and prompts and models change only by a release. A concern of 0.70 opens a proposed case and 0.85 pages the specialist; overriding an agent's proposal needs a reason code such as "Purpose verified with the member".
A complete trail and an examiner export packWho, what, when, why and which evidence, for people and agents alike, kept 5 years under the Bank Secrecy Act with legal hold. The export pack for the NCUA examiner, internal audit or the BSA Officer carries the timeline, sign-offs, training records and agent versions, with other members redacted.
Configuration

Your elder protection policy and your state's hold law, not ours

The steps, limits and clocks the agents follow are settings. A change is a new version, and limit changes are approved by the BSA Officer.

SettingDefaultChoose from
Delay a disbursement5 business daysBranch manager approves; the maker never approves their own
Longer delay15 business daysBSA Officer approves; longer only by court order
Report to Adult Protective Services2 business daysBSA Officer approves every report; the specialist uploads it
Eligible adult65 or olderSet to match the state elder financial exploitation hold law
Delay notice2 business daysTo the member and every authorized party not reasonably believed to be involved
Concern thresholds0.70 opens a proposed case; 0.85 pages the specialistA member at a branch always pages
Member at a branch now1 hour to the first protective stepA missed clock goes to the BSA Officer
Retention5 yearsUnder the Bank Secrecy Act; legal hold; other members redacted in exports
Connections

Works with the systems a credit union already runs on

Core banking systemmembers, owners, trusted contacts and powers of attorney; approved delays written back
Branch teller platformthe Report a concern button and holds at the window
Transaction monitoring systemalerts on members 65 or older
Digital banking and card processordevices, sign-ins, payees and debit card purchases
Learning management systemSenior Safe Act training records
State APS reporting portalthe approved report, uploaded by the specialist with its reference recorded
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
1hour
at most from a branch report to the first protective step, while the member is still there
Oftenafter the check has cleared
With agentsunder 1 hour
target
5of 5
policy steps documented for every case, with who decided, why and on which evidence
typical
0
SAR mentions on any member, joint owner, trusted contact or branch view (31 U.S.C. 5318(g)(2))

“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate of where a concern's working hours go · “typical” = published figures: FinCEN Financial Trend Analysis on elder financial exploitation, April 2024 (155,415 reports, about $27 billion of suspicious activity, about 80% scams; FinCEN notes the total may be overstated), and the AARP estimate of $28.3 billion a year cited in the Interagency Statement on Elder Financial Exploitation, December 2024. Rules: FinCEN Advisory FIN-2022-A002; the Senior Safe Act, 12 U.S.C. 3423; SAR confidentiality, 31 U.S.C. 5318(g)(2). The demo state's hold law settings illustrate one state's rules; yours follow your state. Norrell Federal Credit Union, its members, the companies and the people named on this page are fictional — characters and sample data in the working solution.

Questions

What credit unions and banks ask about elder financial exploitation.

What is Elder Financial Exploitation Detection?

Elder Financial Exploitation Detection is software for credit union and bank fraud and BSA teams that spots elder financial exploitation in the people around an older member's money, then prepares each protective step for a person to decide. Seven agents show who is new and when they appeared, compare the money moves with the member's own pattern, lay out the steps of the institution's policy with their clocks, and draft the guides, the delay notice, the APS report and the SAR referral. A delay and an APS report each need a second person.

What are the red flags of elder financial exploitation?

In the working solution's sample case they arrive in sequence: a new joint owner, a changed phone number two days later, online banking from a new phone, a new payee, first-ever gift cards, an early certificate closure payable to the new person, and a third party answering for the member at the window. The Pattern agent uses FinCEN's advisory FIN-2022-A002 red flags as its reference and cites each signal to its record. Any one alone would score low; together they explain the concern.

Can a credit union delay a disbursement when it suspects elder financial exploitation?

Where a state hold law allows it, yes, and the solution follows the law you set. In the demo state, the delay notice goes within 2 business days to the member and every authorized party not reasonably believed to be involved, and a delay runs up to 15 business days unless a court extends it. The Policy agent computes the clocks; the specialist sends the delay and a second person approves it.

How does it handle the APS report and the SAR?

The Drafting agent fills the state adult protective services report from the case, each value cited; the BSA Officer approves it, and the specialist uploads it to the state portal and records the reference. The SAR referral carries FinCEN's key term EFE FIN-2022-A002 and the 30-day filing clock, and it never appears on a member, joint owner, trusted-contact or branch view.

What can we tell a trusted contact person?

Only what the member's consent on file and her answers today allow. The Safeguards agent checks the call guide before the call: within consent, no amounts or accounts, no report named. A wider scope needs the member's consent that day.

How does it check Senior Safe Act training?

It reads training records from your learning management system and confirms that each employee who reports on a case is current before an APS report is approved. An untrained reporter is flagged and routed. Training is a condition of the Senior Safe Act's protection.

Do people stay in control of each decision?

Yes. The agents notice, map, draft and check; they never hold, release, send, file or change a member record. A person decides every step, the person who proposed a step never approves it, and overriding an agent's proposal needs a reason code.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents (your elder protection policy, your state's hold law, your notice templates and a sample of past cases), and it goes live once every quality gate has passed. We will walk you through it on your own cases first.

See it on
your members' cases.

We'll run Elder Financial Exploitation Detection on a sample of your own past elder exploitation cases.