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.

1/26/10 Customer Identification Program Address Requirement May Be Satisfied by State Agency Address Where Customer Is Victim of Domestic Violence
In 31 states, victims of domestic violence, sexual assault, and stalking may arrange to receive their mail under a state program which keeps their physical addresses private. more>>

1/04/10 FinCEN Finds Banks Still Reluctant to Use Certain Exemptions or Provide Services to MSBs
FinCEN has released a report on bank practices and procedures regarding anti-money laundering programs. The Report notes that filing more than one SAR on a customer may trigger an exit strategy for some banks. more>>

10/19/09 Suspicious Activity Reports Relating to TARP Programs Described
The quarterly report to Congress filed in July by the Special Inspector General for the Troubled Asset Relief Program said that Treasury should require Public-Private Investment Fund (PPIF) managers to “provide Treasury with the identities of all of the beneficial owners of the private interests in the fund so that Treasury can do appropriate diligence to ensure that investors in the funds are legitimate.”   more>>

10/5/09 Red Flag Advisories Increase SAR Reporting of Mortgage Rescue Scams
In a recent gathering of agencies dealing with mortgage rescue scams and loan modification frauds, FinCEN detailed its efforts to detect such frauds and to forward information to the law enforcement community.   more>>

8/20/09 Some FBAR Filers Have Until June 2010 to File, and Some May Never Have to File
On June 5, 2009, the IRS announced a temporary suspension of the FBAR filing requirement for persons who are not U.S. citizens, residents, or domestic entities.  On May 6 and June 24, 2009, the IRS posted questions and answers on its website providing relief to those only recently learning of their FBAR filing obligations, with a filing deadline of September 23, 2009.  more>>

8/14/09 Casino Industry Remains Vulnerable to Money Laundering Schemes
The Financial Action Task Force has issued a detailed report on the vulnerabilities of casinos to money laundering and perhaps even terrorist financing, though the FATF acknowledges that no specific instances of terrorist financing have been reported. more>>

6/10/09 FinCEN Proposals Would Apply CTR and Recordkeeping Rules to Mutual Funds
The Financial Crimes Enforcement Network is proposing to add mutual funds to the basic list of financial institutions in 31 CFR 103.11(n). more>>

5/19/09 FinCEN Report Adds New Red Flags for Securities/Futures Industry Participants
FinCEN’s 15th SAR Activity Report: Trends, Tips & Issues, focuses on the securities and futures industries. more>>

5/14/09 FinCEN Proposes Revisions to MSB Definitions, Stored Value Release Expected
FinCEN is proposing revisions to its MSB definitions along with some reorganization of the MSB provisions. more>>

4/6/09 GAO Notes Technology Limitations in SAR System
The Government Accountability Office, in a recent report, praised FinCEN for the steadily increasing numbers of suspicious activity reports being filed, and for some of the outreach that is encouraging institutions to file. more>>

12/15/08 IRS and FinCEN Release MSB Exam Manual: A Compliance Officer Must-Read
FinCEN and the IRS have released a 159-page manual detailing how IRS examiners should conduct anti-money laundering program examinations of money services businesses. The manual is also effectively a blueprint for how internal or external auditors should review the programs. more>>

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>>