A National Strategy to Prevent Scams - "United We Stand"

Why Scams Are Rising Despite Heavy Investment

As Kate Griffin noted, industry and government are investing heavily in prevention. Yet scams continue to grow.

Why?

• Fragmentation across sectors: No single actor sees the entire attack sequence.
• Outdated reporting infrastructure: Federal systems at agencies like the FBI and FTC remain manual and technologically antiquated.
• Regulatory uncertainty: Financial institutions and technology platforms face unclear expectations about what data they can use and share.
• Speed of modern payments: Faster money movement means faster losses.

Joseph Schuster emphasized that many financial institutions are strongly incentivized to prevent fraud as they often bear reputational and financial risk when scams succeed. But legal ambiguity, especially under statutes like the Fair Credit Reporting Act, can chill data-sharing and innovation.

Core Recommendations from the Aspen Report

The report outlines both high-level national reforms and granular operational improvements with more than 180 specific ideas.

1. Elevate Scam Prevention to a National Priority

The report calls for:

• A designated federal lead (or “czar”) to coordinate strategy
• A whole-of-government approach
• Clear national goals and metrics

  Without centralized leadership, enforcement and regulatory actions remain fragmented. 

2. Modernize Law Enforcement Reporting Systems

• Federal reporting portals, including Suspicious Activity Reports (SARs), the FBI’s complaint systems, and the FTC’s databases, require modernization. The report recommends:
• Streamlined, automated reporting
• Backend data interoperability across agencies
• Advanced analytics and AI tools for enforcement

3. Establish Clear Duties to Act Paired with Safe Harbors

 One of the most important themes discussed was the need for:

• Clear expectations for banks, telecom companies, and digital platforms
• Safe harbors that protect companies when sharing scam intelligence in good faith

  Countries like Australia have already codified such frameworks. The U.S. has yet to establish similarly coordinated standards.

4. Build a Cross-Sector Information-Sharing Ecosystem

• Effective scam prevention requires:
• Exchange of scam indicators (malicious URLs, compromised phone numbers, device patterns)
• Interoperable information-sharing platforms
• Privacy-preserving architecture
• Legal clarity to mitigate antitrust and consumer reporting concerns

Joseph noted that industry appetite for collaboration is strong but clarity and guardrails are essential.

5. Consider a U.S. National Anti-Scam Center

• The report explores the idea of a centralized “front door”, potentially something like stopscams.gov, that would:
• Serve as a national reporting hub
• Provide victim resources
• Facilitate coordination among law enforcement
• Support public education campaigns

Social Media and Platform Responsibility 

The discussion also addressed the evolving role of digital platforms.

Scam activity frequently originates through:

• Paid advertisements
• Dating applications
• Direct messaging
• Fake investment websites

Compared to banks, social media companies operate within a less clearly defined regulatory structure. Courts are increasingly developing theories of “platform liability,” but statutory clarity is lacking.

The report urges policymakers to define reasonable expectations for platforms — paired with safe harbors and practical tools that empower prevention rather than merely assign blame.

What Happens Next?

• The key question: who implements this strategy? Kate Griffin emphasized that this is a whole-of-society problem requiring coordinated action by:
• Federal leadership
• Congress
• Financial institutions
• Telecom and digital platforms
• Law enforcement
• Civil society

There have been encouraging developments, including:

• Treasury and State Department sanctions targeting transnational scam networks
• A joint DOJ–FBI–Secret Service initiative targeting Southeast Asian scam operations
  • But much more remains to be done.

Nick Bourke suggested that, one year from now, real success would include:

• But much more remains to be done.
• A designated federal anti-scam lead
• A congressional commission
• Measurable national prevention goals
• Corporate adoption of formalized anti-scam strategies

Joseph Schuster added that industry innovation is ongoing, particularly in artificial intelligence, biometrics, and authentication, but warned that fragmented state-level regulation could complicate progress.

Key Takeaways

Alan Kaplinsky closed the episode with several important observations:

• Fraud and scams are now a systemic threat, not a niche compliance issue.
• Prevention, not just reimbursement, must be the organizing principle.
• Coordination matters as much as authority.
• Good-faith companies need regulatory clarity, not just enforcement pressure.
• Reducing scams strengthens trust in the U.S. financial system and digital economy.

The Aspen report reframes the debate. Rather than assigning blame, it calls for aligned incentives, shared responsibility, and coordinated national action. If the title of the report, United We Stand, becomes reality, the United States may finally begin to bend the curve on one of the most costly and fast-growing threats facing consumers today.

For more insights on consumer financial services developments, visit Ballard Spahr’s Consumer Finance Monitor blog and explore the full Aspen Institute report here.

Consumer Finance Monitor is hosted by Alan Kaplinsky, Senior Counsel at Ballard Spahr, and the founder and former chair of the firm's Consumer Financial Services Group. We encourage listeners to subscribe to the podcast on their preferred platform for weekly insights into developments in the consumer finance industry.

A transcript of the recording will be available soon.