The editors regularly update Red Flags for Suspicious Activities at Financial Institutions when new studies and documents uncover activities that should be regarded as suspicious by personnel at financial institutions. Recently, a study of mortgage loan fraud added new red flags to the checklist. Although the checklist is arranged by specific types of financial institutions, we recommend that compliance personnel and others read the entire checklist from time to time—activity encountered by tellers at a bank one year may, with slight variation, be found by broker-dealers in another year. Criminals adapt crimes to new environments, and compliance officers must be sure that employees adapt their detection skills as well. Click on COMPLIANCE TOOLS to download.

11/4/08 Junket Operators Pose Growing Risks for Casinos
A casino gets a busload of foreign tourists. Ostensibly because of language problems the tour conductor buys chips for the entire group. more>>

10/27/08 Evaluation of Russian Anti-Money Laundering/Counter Terrorist Financing Programs Notes Rapid Progress, but Continuing Presence of Criminals in Banking and Casino Sectors Complicates Enforcement Efforts
The Financial Action Task Force has posted its second mutual evaluation of the Russian Federation with regard to that country’s anti-money laundering and counter-terrorist financing programs. more>>

9/29/08 AML Guidance Describes Risk Issues Facing Real Estate Agents, Accountants, and Trust and Company Service Providers
The Financial Action Task Force, which serves as a policy hub and think tank for the world’s financial intelligence units (including the U.S.’s FinCEN), has issued anti-money laundering/counter terrorist financing guidance for accountants, real estate agents, and trust and service company providers. more>>

8/27/08 Proliferation Financing Study Describes Red Flags, Role of Financial Institutions
A U.S. manufacturer receives an order from a Belgian broker for a high energy switch that can be used in a number of manufacturing processes, many of which are conventional, but some of which involve making nuclear bombs. more>>

7/29/08 Use of Internet Payment Systems by Launderers Is Focus of FATF, DOJ Reports
FinCEN, the Department of Justice, and the Financial Action Task Force have all expressed concern with the ways that the internet can be used by money launderers and terrorist financiers. more>>

7/08/08 Allocation of Responsibilities Between Introducing and Clearing Brokers Permitted, But Domestic or Foreign Status of Introducing Broker Must Be Taken Into Account
When a clearing broker has customers introduced to it by an introducing firm, it can avoid customer identification program (CIP) responsibilities as to the introduced clients if the functions of opening and approving customer accounts and directly receiving and accepting orders from the introduced customer are allocated exclusively to the introducing firm. more>>

6/17/08 Security System For Internet Customers Is Money Transmitter, FinCEN Rules
Providing customers with greater security in making internet purchases resulted in the company providing the security being denominated a money services business by FinCEN. more>>

5/15/08 Some Foreign Exchange Activities May Not Make a Business an MSB
A currency dealer or exchanger is a type of money services business, as is a money transmitter. Most businesses providing foreign currency exchange services will, therefore, be MSBs. more>>

5/9/08 Following GAO Report, FinCEN Proposes Easing CTR Exemption Process
Banks do not need to file currency transaction reports on “exempt persons,” which include other banks, government agencies, entities established by governments, and exchange-listed companies and certain subsidiaries. more>>

3/31/08 Guidance Describes How Dealers in Precious Metals, Precious Stones, and Jewels Should Evaluate Foreign Suppliers
Interim final rules issued in 2005 required dealers in precious metals, precious stones, and/or precious jewels to develop anti-money laundering programs by January 1, 2006. more>>