Money Laundering, Terrorism & Financial Institutions - USA Patriot Act Monitor
Published by Civic Research Institute
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December 2014 Virtual Currency Trading Platform Is Money Transmitter
November 2014 Virtual Currency Payment System Is Money Transmission
October 2014 LA Fashion District Targeted as Part of Drug Cartel Crackdown
September 2014 FinCEN Proposes Rules on Identifying Beneficial Owners
August 2014 FinCEN Seeks to Promote Culture of Compliance
July 2014 BNP Paribas Fined $9 Billion for Sanctions Violations
June 2014 Funnel Accounts Become Popular with Mexican Drug Cartels
May 2014 Company Providing Real-Time Services Is MSB
April 2014 Virtual Currency Transactions Have Tax Consequences
March 2014 Yanukovych and His Allies May Be Absconding Ukrainian Assets
February 2014 Providing Financial Services to “Legal” Marijuana Businesses
January 2014 JP Morgan Chase Pays $2.05 Billion for Failing to File SARs on Madoff
December 2013 Treasury Revises Definitions of “Fund Transfer” and “Transmittal of Funds”
November 2013 Secondary Market Does Not Take Prepaid Access Company Out of 2011 Rule
October 2013 TD Bank Failed to Report $1 Billion in Suspicious Transactions
September 2013 Statistics Reveal Concentration of Mortgage Fraud in 2006 and 2007
August 2013 Virtual Economies and Currencies Create Unresolved Tax Issues
June 2013 FinCEN Goes After Web-Based Money Transfer System
May 2013 Elder Financial Exploitation Subject of FinCEN Study
April 2013 Some Operations with Virtual Currencies Are Deemed MSBs
March 2013 DHS Ten Years After 9/11
February 2013 Arab Bank Sued by Victims of Terrorism
January 2013 Inspector General Evaluates Information Security at DHS
December 2012 HSBC Settles Massive Bank Secrecy Violations for Hefty Fine, but No Jail Time
November 2012 Third-Party Payment Processors Pose Risks for Banks
October 2012 Information Conduit Company Owned by Financial Institutions Advised to Modify Operations
September 2012 Motor Vehicles, Vessels, and Aircraft for the CTR Exemption
August 2012 Treasury Inspector General Looks at Tax Refund Fraud
July 2012 FinCEN Focuses on SARs Filed by Money Services Businesses
June 2012 IRS Computer Incident Response Center Needs Improvement
May 2012 Floats Ideas on Information Financial Institutions Will Have to Obtain on Beneficial Owners
April 2012 Aggregating Multiple Transactions for CTR Reporting by Closely Controlled Businesses
March 2012 FATF Paper on Information Sharing To Stop Proliferation
February 2012 Non-Bank Residential Mortgage Lenders Must Establish AML Programs, File SARs
January 2012 New Phishing Software Displays False Account Information Inside Bank Webpages
December 2011 Transportation Industry Provided Good but Not Always Useful Terrorism Information
November 2011 Freddies Mae and Mac and Home Loan Banks to Be Covered by AML, SAR Rules
October 2011 High Seas Piracy is Becoming Big Criminal Business
September 2011 Identity Theft in the Securities Industry Analyzed by FinCEN
August 2011 FinCEN Issues Final Prepaid Access Rules
July 2011 Bank Has No Duty to Noncustomer for Customer's Fraudulent Conduct
June 2011 Tax Return Fraud Becomes Increasingly Popular with Identity Thieves
May 2011 FinCEN Rules Would Look Through Domestic Banks to Find Iranian Transactions
April 2011 Guidance Provided on Accepting Accounts from Foreign Embassies

March 2011

FinCEN’s Chapter X of Title 31 Now a Reality (Really)
February 2011 FinCEN Issues Warning to U.S. Institutions on Upheaval in Tunisia
January 2011 Failure to Register Leads to $12,000 Fine for Money Transmitter
December 2010 The Financial Crimes Enforcement Network has issued several releases regarding the confidentiality of Suspicious Activity Reports
November 2010 FinCEN Finally Publishes Chapter X
October 2010 Cross-Border Funds Transmittals Reporting Requirements Proposed
September 2010 Cuckoo Smurfing Requires Sophistication, But Is Increasing In Some Financial Systems
August 2010 Iran Sanctions Act Requires U.S. Financial Institutions Look at Users of Foreign Exchange and Correspondent Services
July 2010 Gift Cards and Other “Prepaid Access” Arrangements Get New Look from FinCEN
June 2010 FBAR Requirements Elaborated (Again)
May 2010 Money Laundering in the Football Sector
April 2010 Hiring Incentives Act Contains Tax Changes for Institutions, Investors
March 2010 FinCEN and Regulatory Agencies Describe Beneficial Ownership Best Practices
February 2010 Law Enforcement Requests to Financial Institutions May Now Come from Foreign and State and Local Agencies, and FinCEN Itself
January 2010 FinCEN Issues Bank Report
December 2009 FBI and ICE Agents Talk About SARs
November 2009 Filing SARs on TARP Programs
October 2009 FinCEN Posts FAQs on Gaming Industry
September 2009 Armored Car Service Was Agent of Customers, Not Bank, in FinCEN Ruling
August 2009 FinCEN Looks at Securities and Futures Industry in 15th SAR Activity Review
July 2009 Mutual Funds To Be “Financial Institutions” Under FinCEN Proposal
June 2009 GAO Report Describes How SAR Information Is Disseminated Across Agencies Involved in Investigative and Enforcement Efforts
May 2009 FinCEN Joins Search For Fraud in TARP Program
April 2009 Arranger of Financing Was Not Money Transmitter
March 2009 FinCEN Revises CTR Exemption Rules
February 2009 FinCEN Proposes New Chapter for BSA Regulations
January 2009 UK Reviews AML Systems of Private Banks
December 2008 When is a Broker or Dealer in Currency a Money Transmitter?
November 2008 Red Flags for Casinos and Card Clubs Posted by FinCEN
October 2008 FinCEN Revises CTR Form for Casinos
September 2008 System Securing Online Purchases For Customers Is a Money Transmitter
August 2008 Three Forex-Related Businesses Try Not to Be MSBs
July 2008 FinCEN Proposes Revisions to CTR Exemption Procedures
June 2008 “Foreign Corruption” Should Be Spelled Out in SAR Narratives, If Present
May 2008 Wire Transfer Requirements Subject to Further Elaboration by the FATF
April 2008 Precious Metal, Stone, and Jewel Dealers Advised on Risks of Foreign Suppliers
March 2008 Presenting Negotiable Instruments Does Not Create Correspondent Account
February 2008 Lender’s Cashing of Checks For Borrowers Does Not Make It a Check Casher
January 2008 12th SAR Activity Review Looks at Credit Card Checks, Credit Union Cooperatives, and Law Enforcement Successes
December 2007 FinCEN Finds Persistent Failures in SAR Filings by Many MSBs
November 2007 Enhanced Correspondent Account Due Diligence Rules Finalized
October 2007 FATF Mutual Evaluation of China Finds Progress, Also Significant Deficiencies
September 2007 Transaction Reporting Changes for Casinos Finalized by FinCEN
August 2007 FinCEN Issues SAR Activity Review, Issue 11
July 2007 Customer ID Program Guidance for FCMs in Give-Up Arrangements Issued
June 2007 Macau Bank Helping North Korean Counterfeiters Gets Pariah Status, But FinCEN Releases Frozen Funds Weeks Later
May 2007 FATF Plenary Session Grants India Observer Status
April 2007 Suspicious Activity Reports Revised For Joint Filings
March 2007 Jurisdictional Overlaps and Lack of Coordination Plague Partnership of IRS and FinCEN in BSA Enforcement
February 2007 Bank Selling Insurance as Agent Does Not Open Accounts for CIP Purposes
January 2007 Currency Transaction Reporting to Be Studied by OCC
December 2006 Mutual Fund Suspicious Activity Reporting Subject of FinCEN FAQs
November 2006 New Materials Added to FFIEC Exam Manual Describe Automated Clearing House and Other Requirements
October 2006 Mutual Evaluation of U.S. AML and Counter-Terrorism Efforts Throws Mix of Soft and Hardballs
September 2006 FinCEN’s Focuses Attention on MSBs in 10th SAR Activity Review
August 2006 FinCEN’S SAR By the Numbers Report Notes Increase in Market Manipulation
July 2006 Cashing Its Own Checks Does Not Make a Business a Check Casher
June 2006 BSA Compliance Rules for Edge Act and Agreement Corporations Finalized
May 2006 OFAC Provides Best Practices for Bank Compliance, Details Review Procedures
April 2006 Chief Counsel Considers When Offshore Credit Card Accounts Are Financial Accounts for FBAR Reporting and Penalties
March 2006 Final Due Diligence Rules on Correspondent and Private Banking Accounts Issued The use of correspondent and private banking accounts for money laundering was a concern before the PATRIOT Act, but Section 312 of the Act required U.S. financial institutions to establish due diligence policies, procedures, and controls reasonably designed to detect and report money laundering through such accounts.
February 2006 Terrorism Risk Insurance Extension Act Keeps Program Alive Two More Years; The Terrorism Risk Insurance Extension Act of 2005 (“Extension Act”)1 extends the federal safety net for insurers for two years, but expands the private sector role and reduces the federal share of compensation for insured losses under the program.
January 2006 U.S. Terrorist Financing Strategy Found Deficient; In Terrorist Financing: Better Strategic Planning Needed to Coordinate U.S. Efforts to Deliver Counter-Terrorism Financing Training and Technical Assistance Abroad,1 the Government Accountability Office found the U.S. government “lacks an integrated strategy to coordinate the delivery of counter-terrorism financing training and technical
December 2005 Inspector General Reports Widespread Failure to Register by MSBs; In Bank Secrecy Act: Major Challenges Faced by FinCEN in Its Program to Register Money Services Businesses,1 the Treasury Inspector General found “indicators that many MSBs required to register had not done so.” The OIG Report acknowledged a 37% increase in registrations between January 2004 and January 2005, a numerical increase from 16,142 to approximately 22,000, with no enforcement actions taken against noncompliant MSBs.
November 2005 Comptroller Discusses Effects of Uniform Examination Procedures; John C. Dugan, Comptroller of the Currency, in a speech delivered before the American Bankers Association/American Bar Association Money Laundering Enforcement Conference on November 1, 2005,1 stated that the OCC is applying the new uniform examination procedures in all bank examinations.
October 2005 The recently issued FFIEC BSA/AML Examination Manual is more detailed than prior exam manuals issued by the banking regulators separately, particularly as to issues involving electronic operations, organizational structures, and relationships with other financial institutions.
September 2005 Three Recent FinCEN Rulings Refine Definition of MSB; Continuing its trend to providing piecemeal but almost immediate guidance on Bank Secrecy Act issues, FinCEN recently released three rulings describing borderline situations where a business might, or might not, be an MSB.
August 2005 Seven New Members to Egmont Group; The Egmont Group, which met from June 27 to July 1 in Washington, D.C., admitted seven new members: Bosnia/Herzegovina, Honduras, Peru, Philippines, Montenegro, Qatar, and San Marino. This brings the total membership of the ten-year old organization to 101. The tenth anniversary meeting was hosted by FinCEN.1
July 2005 A financial institution for purposes of the Bank Secrecy Act includes, under 31 U.S.C. 5312(a)(2)(N), “a dealer in precious metals, stones, or jewels.” On April 29, 2002, FinCEN deferred anti-money laundering program requirements for such entities.1 On June 3, the Financial Crimes Enforcement Network posted interim final rules describing the anti-money laundering programs that must be established by dealers in jewels, precious metals, or precious stones.2 The effective date is July 11.
June 2005 Guidance on Customer ID Programs Provided by FinCEN, Banking Agencies Special Measures Proposed for Two Latvian Banks, Electronic Filing of SARs and CTRs Continues to Grow, Agroterrorism Seen as Continuing Threat in GAO Study, SAR Narratives Often Inadequate, FinCEN Finds, FATF Website Redesigned
May 2005 Eighth SAR Review Talks About “Racinos,” National Security Letters, Other Trends and Developments, Pinochet Matter Continues to Fuel Investigations, FinCEN Proposes SAR for MSBs, State Department Lists Countries of Primary Concern for Money Laundering
April 2005 FinCEN Issues 2004 Annual Report; FCMs and Introducing Brokers May Rely on CTAs to Perform CIP; Cook Islands, Philippines Advisories Withdrawn; BSA Exam Guidelines Revisions Expected; OCC Unauthorized Bank List; UN Terrorist List Can Supplement SDN List; Companies Associated With Jamaican Drug Kingpin Designated
March 2005 Cook Islands, Indonesia, and the Philippines Removed from NCCT List; FATF Issues Additional Guidance on 9th Special Recommendation; SAR Activity Review Statistical Data Updated; FinCEN Releases 2006-2008 Strategic Plan; Arellano Felix Organization Described by Treasury
February 2005 Intelligence Reform Act Gives New Power to FinCEN, Other Agencies; FinCEN Revises MSB Registration Form; Secure Web System for 314(a) Communications Launched by FinCEN
January 2005 Interpretive Guidance Describes AML Programs of Money Services Businesses; Unitary Filing of Suspicious Activity and Blocking Reports Detailed in Interpretive Guidance; Narcotics Trafficking List Expanded To Include More Columbian Drug Lord Agents; Cali Cartel Financial Network November 2004
December 2004 OCC Issues Enforcement Guidance on Issuing Cease-and-Desist Orders for BSA Violations; Foreign Financial Account Reporting Penalty Can Now Be Imposed Without Willfulness; OFAC Adds Peruvian Airline to Kingpin List; Survivor Vanuatu: State Department Lists Offshore Financial Centers
November 2004 FATF Adds Ninth Special Recommendation; FATF Withdraws Counter- Measures Against Myanmar and Nauru; Two New Regional Groups Being Formed; Increase in Defensive Filings Noted by FinCEN; 314(a) Statistics Released; UK Considers Revisions to Customer ID Procedures
October 2004 AmSouth Bank Fined $10 Million For BSA Violations, Prosecutions Deferred; China Increases Money Laundering Effort; Shift to Counterterrorism Priorities May Have Reduced FBI’s Drug Enforcement Efforts
September 2004 Seventh SAR Activity Review Released; Shell Corporations and Shell Banks; Food Stamp Fraud; International Cash Letters; Refund Anticipation Loan Fraud; Suspicious Activity Reporting by Broker-Dealers; ATMs Can Avoid Bank Secrecy Reporting
August 2004 SEC Finds No Evidence of Trading Patterns Indicating Advance Knowledge of 9/11; Report Slams Riggs Bank AML Implementation, Regulators on Enforcement; India AML Progress Analyzed by Drs. J.D. Agarwal and Aman Agarwal; FinCEN Magnetic Media Filing Specifications Updated; SIA Comments on Special Measure Against Commercial Bank of Syria; Customer Identification Program Exam Procedures Described by Bank Regulators
July 2004 FATF Issues Annual Report, Announces Initiatives; Fifth Annual Review of Non-Cooperative Countries or Territories Released by FAFF; Guatemala Dropped from List; Interpretive Guidance Focuses on Terrorist Financing; Supervisory Agencies Provide Tepid Encouragement For Financial Services To Embassies and Foreign Governments; FinCEN Reinstates Information Sharing with Mexico; Phishing Hits OCC
June 2004 Riggs National Bank Assessed $25 Million For BSA Violations; Terrorism Risk Insurance May Not Continue Without Government Support; FATF Renews Mandate for Eight Years; FinCEN Summarizes Protections for SAR Filers; Phishing Schemes Nearly Doubling EveryMonth
May 2004 Foreign Currency Exchanger Does Not Become MSB By Keeping Account In U.S.; Special Measures On Burma Imposed; Two Syrian Banks Designated Of Primary Money Laundering Concern; FinCEN Director Describes Coming Releases, Developments; Treasury Department Requests Comments On Whether To Extend “Make Available” Requirements of Terrorism Risk Insurance Act; SAR Statistics Released; GAO Finds Cargo Containers A Continuing Security Threat
April 2004 No-Action Letter Opens Door For Broker-Dealers to Rely on Investment Advisers for Customer Identification Requirements; International Narcotics Control Strategy Report Released; Advisories on Egypt, Ukraine Withdrawn; Financial Services Authority Fines Austrian Bank; FinCEN Proposes Two Currency Transportation Forms
March 2004 New Money Laundering Typologies Report Released by FATF; Ukraine and Egypt Removed from Non-Cooperative Countries and Territories List; National Strategies Related to Terrorism Evaluated by GAO; Money Services Business Registration List Added to FinCEN Website; District Court Protects Bank’s SAR-Related Records
February 2004 FinCEN Provides Guidance on Suspicious Activity Reporting for Casinos; GAO Says FBI Should Study Terrorists’ Use of Alternative Financing Mechanisms; Customer Identification Program FAQs Provided by Agencies; Comment on Real Estate Closers Made by Bureau of Alcohol, Tobacco, Firearms and Explosives; FinCEN Warns of Anti-Terrorist Certificate Scam
January 2004 Final Rules Require FCMs and Introducing Brokers to File SARs; New Currency Transaction Report Form Issued; National Money Laundering Strategy Restated for 2003; Claims Procedures under Terrorism Risk Insurance Act Proposed; Broker-Dealer Fined for Foreign Shell Bank Correspondent Accounts; FinCEN Reiterates Requirements for Ruling Requests; Contact Information of National Banks To Be Processed Electronically
December 2003 GAO Finds Leadership, Priorities, and Accountability Deficient in National Money Laundering Strategy; CD for MSBs Provides Educational Tools, Forms, and Contact Information; New SAR Activity Review Released; Travel Rule Exception Expires Permanently
November 2003 Examination Procedures Specified on Foreign Shell Banks and Information Sharing; FinCEN Report Looks At Seven Years of SAR Filings; Small Changes to Interim Terrorism Risk Insurance Rules; Financial Institutions Reacted Effectively to August Blackout; James Sloan Leaves FinCEN; Terrorist Supporter Allegedly Connected With Lichtenstein Bank
October 2003 FATF Focuses on Freezing Terrorist Assets; Customer Identification Rules Do Not Require Retention of Photocopies and Do Not Preclude Foreign Government Issued IDs Other Than Passports; FinCEN’s Freedom of Information Act and Privacy Act Procedures Modified for Bureau Status
September 2003 Treasury Touts Progress Against Terrorist Financing; UK Financial Services Authority Considers Changes to Customer Identification Standards; GAO Report Recommends Improvements to Information Sharing Procedures; GAO Warns of Vulnerabilities at Land Border Points of Entry
August 2003 Treasury Adopts Final Terrorism Risk Insurance Program Rules, Making Minor Modifications to the Interim Version
July 2003 FATF Releases New Forty Recommendations; Other Developments Mark Plenary Meeting
June 2003 Edge and Agreement Corporations Subject to Be Subject to BSA Under Proposed Rule
May 2003 Investment Advisors and Commodity Trading Advisors to be Required to Implement Anti-Money Laundering Programs
April 2003 Terrorism Risk Insurance Program Takes Shape through Interim Rules
March 2003 Jewelers and other Dealers Required to Implement Anti-Money Laundering Programs
February 2003 Currency Dealers and Exchangers Now Required to File Suspicious Activity Reports
January 2003 Suspicious Activity Reporting for Mutual Funds Contained in Proposed Rules
December 2002 Treasury Report Acknowledges Difficulties in Identifying Foreign Nationals
November 2002 Hedge Funds and Other Unregistered Investment Companies Will Soon Be Required to Establish Anti-Money Laundering Programs

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