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.

Welcome to the Online Edition

Cover IllustrationThe Online Edition of Money Laundering, Terrorism, and Financial Institutions includes the complete text of the loose-leaf service, fully searchable; all USA Patriot Act Monitors published to date; comprehensive checklists for compliance with anti-money laundering regulations; and links to thousands of government documents related to anti-money laundering law.

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Updates and commentary on newly issued and proposed regulations implementing the USA Patriot Act.
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.
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.
Releases concerning money laundering and terrorism from the Federal Register.
Laws and Congressional Activities Concerning Money Laundering and Terrorism
Releases of Federal Agencies Concerning Money Laundering and Terrorism.
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

5/09/2012 FinCEN May Require New "Beneficial Owner" Disclosures from Financial Institutions.      
Effort seeks to counter attempts by criminals, terrorists, and even legitimate entities attempting to hide the identities of investors.  more>>

10/13/2011 Piracy for Ransom Increasingly Lucrative, Ventures Sometimes Syndicated 
A report by the Financial Action Task Force on piracy describes the increasingly lucrative nature of the business of holding ships and crews for ransom, as well as the difficulty that the international community faces in stopping piracy on the high seas. more>>

9/24/2011 Business Travelers Beware: Free Hotel Computers Providing Internet Access Can Be Hacked 
Ever check your bank balance on a hotel computer?  A recent government report describes an identity thief who traveled around the country, staying at high-end hotels, who installed a virus on computers available to the guests. more>>

2/14/2011 Mideast Developments Get FinCEN’s Attention
The upheaval in Tunisia and Egypt has not gone unnoticed by the Financial Crimes Enforcement Network. The agency has issued a warning to U.S. financial institutions that “senior foreign political figures” may be fleeing Tunisia and trying to take out money that does not belong to them. more>>

1/11/2011 Major Study of New Payment Methods Released by FATF
The Financial Action Task Force, which provides guidance for financial intelligence units around the world, including FinCEN in the United States, has issued a report on new payment methods (NPMs) more>>

12/06/2010 FinCEN Tweaks and Tightens SAR Confidentiality Requirements
FinCEN has tightened the rules allowing state and tribal authorities to get SAR filing information from institutions regulated by such authorities. There appears to have been a concern that state and tribal authorities, if they are not overseeing institutions regarding BSA requirements, should not have access to confidential SAR information. more>>

09/13/2010 Cuckoo Smurfing Requires Sophistication, But Is Increasing In Some Financial Systems The tactic was originally identified by Australian authorities in 2008
The Financial Action Task Force has issued a global threat report describing money laundering and terrorism financing threats, looking particularly at new trends. more>>

7/8/2010 The Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010
The Comprehensive Iran Sanctions, Accountability, and Divestment Act of 2010, Pub. L. 111-195, imposes additional economic sanctions in an effort to stop or at least impede Iran’s nuclear program and terrorist activities. more>>

7/1/2010 FinCEN Proposes New Rules on Gift Cards and Other Prepaid Access Devices
A gift card is one of the simpler types of “stored value” devices included under the anti-money laundering regulations.  A transit card for the New York City transit system is another.  Unfortunately for FinCEN, which introduced regulations regarding such devices in 1997, the terminology of the industry has evolved and “stored value” is not widely used, nor really accurate. more>>

6/9/2010 Savings Bank Had Numerous MSB Customers, Yet Did Not Distinguish Customers with Heightened Risks
Pamrapo Savings Bank of Bayonne, New Jersey, has been fined $1 million for Bank Secrecy Act violations. Reading the enforcement action, one wonders why the fine was so lowmore>>

3/22/10 Hiring Incentives Act Contains New Witholding Requirements
IThe new law includes provisions that make it easier for the IRS to monitor accounts at foreign financial institutions.
On March 18, President Obama signed the Hiring Incentives to Restore Employment Act (PL 111-147), designed to encourage the hiring of unemployed workers, providing payroll tax forgiveness for hiring unemployed workers and a business tax credit for retention of newly hired individuals in 2010. more>>

3/12/10 No-action Letter for Broker-Dealers’ Having Registered Investment Advisers Perform CIP Function Adds New Requirement
IEvery two years, the SEC has issued a no-action letter providing that broker-dealers may rely on registered investment advisers to perform customer identification program functions. As expected, a no-action letter was issued on January 11 to the Securities Industry and Financial Markets Association. more>>

2/16/10 FinCEN Expands Information Sharing Coverage to Include Foreign Law Enforcement Agencies
IFinancial institutions can expect to begin receiving information sharing requests from foreign law enforcement agencies under rules adopted by FinCEN in February. more>>

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>>

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