Money Laundering, Terrorism and Financial Institutions - USA PATRIOT ACT Monitor
Published by Civic Research Institute
 

Money Laundering, Terrorism and Financial Institutions
Law • Regulation • Compliance
Editors: Raymond Banoun, J.D. and John Ensminger, J.D., LL.M.
 
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Contents
 
USA PATRIOT ACT MONITORS
Updates and commentary on newly issued and proposed regulations implementing the USA Patriot Act.
COMPLIANCE TOOLS
Checklists for compliance with the Bank Secrecy Act, the USA PATRIOT Act, the Intelligence Reform and Terrorism Prevention Act, and related regulations and government guidance.
MONEY LAUNDERING, TERRORISM & FINANCIAL INSTITUTIONS
Online edition of loose-leaf service.
Updates to Looseleaf-Service: New and replacement pages updating your Money Laundering Terrorism and Financial Institutions loose-leaf service.
FEDERAL REGISTER
Releases concerning money laundering and terrorism from the Federal Register.
LEGISLATIVE MATERIALS
Laws and Congressional Activities Concerning Money Laundering and Terrorism
AGENCY REPORTS
Releases of Federal Agencies Concerning Money Laundering and Terrorism.
ANTI-MONEY LAUNDERING COMPLIANCE FLOW CHART
Step-by-step “Compliance Flow Chart”  details every key relationship and requirement for money-laundering compliance.
  Just Released!  New Compliance Checklist for Suspicious Activities

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.

USA PATRIOT ACT Monitor News Releases

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>>

3/4/08 Container Security Initiative Targets High Risk Cargo for Inspection at Foreign Seaports
Imagine: a dirty bomb is found in the Port of Newark. An agent of Al Qaeda is arrested in Baltimore and admits that he is part of a team to bring dirty bombs into five U.S. ports. more>>

1/14/08 SEC Registration of Securities Does Note Exclude Business From MSB Definition
inCEN previously considered whether a tax return preparer that cashed checks for customers for whom it made refund anticipation loans was a check casher, and thus a type of money services business. more>>

12/19/07 FinCEN Posts FAQs for Casinos
The Financial Crimes Enforcement Network has posted answers to a number of frequently asked questions regarding the AML responsibilities of casinos. more>>

11/5/07 FinCEN Describes Risks of Convenience Checks
FinCEN’s 12th SAR Activity Review discusses how credit card convenience checks have become popular with identity thieves. more>>

10/11/07 FinCEN Finds Persistent Failures in SAR Filings by Many MSBs
The Financial Crimes Enforcement Network has found that certain common errors are appearing in suspicious activity reporting by money services businesses and the agency has released a list of the ten most common errors. more>>

8/17/07 Enhanced Due Diligence Rules on Correspondent Accounts for High-Risk Foreign Banks Finalized
Rules implementing enhanced due diligence requirements under section 312 of the USA PATRIOT Act for domestic institutions maintaining accounts for certain high risk foreign banks have been made final. more>>

8/9/07 FATF Mutual Evaluation of China Finds Rapid Progress, But Significant Deficiencies
The Financial Action Task Force has completed a mutual evaluation of China and posted a summary, though not yet the full report. more>>

7/9/07 Currency Transaction Reporting Rules Lighten Some Requirements for Casinos
Final rules modifying currency transaction reporting requirements for casinos attempt to lighten the reporting load that has been placed on casinos and card clubs. more>

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