Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor

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9/9/2004 USA PATRIOT Act Monitor News Release: Further ATM Regulation May Come From FinCEN Analysis

The seventh SAR Activity Review notes that ATMs are being used by drug dealers to deposit illicit proceeds, sometimes in structuring transactions that may escape currency transaction reporting. Dealers may make multiple deposits or withdrawals from different ATMs, or may use a combination of ATMs and tellers. Some dealers deposit cash in U.S. ATMs, then withdraw it at ATMs in countries in the drug pipeline, particularly Colombia. Financial institutions in Florida are, according to FinCEN, filing the majority of Suspicious Activity Reports regarding such activities. Florida is popular both because it is a hub of drug activity and because of its cash intensive economy, which makes detecting drug-related cash transactions more difficult The SAR Review indicates that FinCEN is continuing to study the problem, working with law enforcement and the "regulatory community." Presumably, regulators are being involved because additional oversight may be necessary to deal with this complex problem. FinCEN's analysis will be discussed in more detail in the September issue of the Monitor.

© 2004 , all rights reserved. The USA PATRIOT Act Monitor and accompanying news releases are published by the Civic Research Institute, 4478 U.S. Route 27, P.O. Box 585, Kingston, NJ 08528, 609-683-4450, civres@comcast.net, www.civicresearchinstitute.com/moneylaundering. The Monitor and the news releases are an update service for Money Laundering, Terrorism and Financial Institutions: Law Regulation Compliance, by Raymond Banoun and John Ensminger. The information in this publication is not intended to replace the services of a trained legal professional.

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