A customer accesses a safe deposit box after completing a transaction involving a large withdrawal of currency, or accesses a safe deposit box before making currency deposits structured at or just under $10,000, to evade CTR filing requirements.A customer deposits funds into several accounts, usually in amounts of less than $3,000, which are subsequently consolidated into a master account and transferred outside of the country, particularly to or through a location of specific concern (e.g., countries designated by national authorities and Financial Action Task Force on Money Laundering (FATF) as noncooperative countries and territories).A person customarily uses the automated teller machine to make several bank deposits below a specified threshold.A business or customer asks to be exempted from reporting or recordkeeping requirements.A customer is reluctant to furnish identification when purchasing negotiable instruments in recordable amounts.A customer is reluctant to provide information needed to file a mandatory report, to have the report filed, or to proceed with a transaction after being informed that the report must be filed.A customer or group tries to persuade a bank employee not to file required reports or maintain required records.Beneficial owners may hire nominee incorporation services to establish shell companies and open bank accounts for those shell companies while shielding the owner’s identity.Įfforts to Avoid Reporting or Recordkeeping Requirement A customer is a trust, shell company, or Private Investment Company that is reluctant to provide information on controlling parties and underlying beneficiaries.A customer makes frequent or large transactions and has no record of past or present employment experience.The customer’s background differs from that which would be expected on the basis of his or her business activities.A customer’s home or business telephone is disconnected.A business is reluctant, when establishing a new account, to provide complete information about the nature and purpose of its business, anticipated account activity, prior banking relationships, the names of its officers and directors, or information on its business location.A customer uses different taxpayer identification numbers with variations of his or her name.A customer provides an individual taxpayer identification number after having previously used a Social Security number.A customer uses unusual or suspicious identification documents that cannot be readily verified.Potentially Suspicious Activity That May Indicate Money Laundering Customers Who Provide Insufficient or Suspicious Information Closer scrutiny should help to determine whether the activity is suspicious or one for which there does not appear to be a reasonable business or legal purpose. The mere presence of a red flag is not by itself evidence of criminal activity. The following examples are red flags that, when encountered, may warrant additional scrutiny. Management’s primary focus should be on reporting suspicious activities, rather than on determining whether the transactions are in fact linked to money laundering, terrorist financing, or a particular crime. The advisories and guidance can be found on FinCEN's website.ģ02 Refer to SAR Advisory Key Terms. In order to assist law enforcement in its efforts to target these activities, FinCEN requests that banks check the appropriate box(es) in the Suspicious Activity Information section and include certain key terms in the narrative section of the SAR. FinCEN issues advisories containing examples of "red flags" to inform and assist banks in reporting instances of suspected money laundering, terrorist financing, and fraud. Although these lists are not all-inclusive, they may help banks and examiners recognize possible money laundering and terrorist financing schemes. The following are examples of potentially suspicious activities, or "red flags" for both money laundering and terrorist financing. APPENDIX F: MONEY LAUNDERING AND TERRORIST FINANCING "RED FLAGS"
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