This guide has two parts: Part A to help you determine whether your business or organization is at low risk, and Part B to help you design your written Identity Theft Prevention Program if your business is in the low risk category.
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The program has four elements: 1) Identify Relevant Red Flags. 2) Detect Red Flags. 3) Prevent and Mitigate Identity Theft. 4) Update Program.
This ITPP addresses 1) identifying relevant identity theft Red Flags for our firm, 2) detecting those Red Flags, 3) responding appropriately to any that are detected to prevent and mitigate identity theft, and 4) updating our ITPP periodically to reflect changes in risks.
Institutions are required to have a written identity theft prevention program (ITPP) to govern their organization and protect their consumers. What's a red flag? The FTC defines a red flag as a pattern, practice or specific activity that indicates the possible existence of identity theft.
The Red Flags Rule requires organizations to implement a written identity theft prevention program to help them identify any of the relevant ?red flags? that indicate identity theft in daily operations. The Rule also offers steps to help prevent the crime and to mitigate its damage.
This ITPP addresses 1) identifying relevant identity theft Red Flags for our firm, 2) detecting those Red Flags, 3) responding appropriately to any that are detected to prevent and mitigate identity theft, and 4) updating our ITPP periodically to reflect changes in risks.
In Anti-Money Laundering (AML) compliance, a red flag describes a warning sign that indicates the possibility of money laundering or other criminal activity. Red flags can include transactions involving companies in sanctioned jurisdictions, large volumes, or funds being transmitted from unknown or opaque sources.
Simply accepting credit cards as a form of payment does not make you a ?creditor? under the Red Flags Rule. But if a company offers its own credit card, arranges credit for its customers, or extends credit by selling customers goods or services now and billing them later, it is a ?creditor? under the law.
