BSA/AML Examiner School Case Study
Internal Use Only
• Gambling Facilities (i.e., 8 liners, video gambling and amusement entertainers, maquinitas) • Casinos and card clubs • Financial institutions such as jewel, gem, and precious metal dealers, pawnbrokers, loan finance co., Travel agencies. • Businesses that engage in vehicle sales, including: car, boat and plane dealerships; used cars or truck dealers; machine parts manufacturers and ship, bus and plane operators. • Foreign corporation and domestic business entities, particularly offshore corporations and banks located in tax or secrecy havens, domestic shell companies and international business corp. • Leather goods stores, Broker/dealers, Import/export companies, Auctioneers, Telemarketers • Deposit brokers, particularly foreign deposit brokers • Professional service providers (lawyers, IOLTA accountants, investment brokers, doctors, real estate brokers) • Cash-intensive businesses, such as convenience stores, restaurants, retail stores, liquor stores, cigarette distributors, privately owned ATMs, vending machine operators and parking garages • Non-government organizations and charities (foreign and domestic) Banking functions and transactions that need special attention: • Offshore international activity • Deposit-taking facilities • International correspondent banking accounts • Electronic and Internet banking • Wire transfers/cash management functions • Transactions in which the primary beneficiary or counterparty is undisclosed • Loan guarantees schemes • Transactions involving large amounts of traveler's checks, official bank checks, money orders and prepaid access cards. • Electronic transactions that permit the rapid movement of currency (i.e.., foreign exchange transactions followed by payment into another jurisdiction). • Electronic funds payment services, such as electronic cash (i.e., stored value), funds transfers (domestic and international), ACH transactions and ATMs • Private banking (domestic and international) • Trade finance (letters of credit) • Lending activities, particularly loans secured by cash collateral and marketable securities • Non-deposit account services (i.e., non-deposit investment products, insurance, etc.) High-Risk Countries • The following countries have been identified by FINCEN (Financial Crimes Enforcement Network) and the FATF (financial Action Task Force) through advisories, warn banks and financial institutions operating in the U.S. that "enhanced scrutiny" must be given to transactions in the following jurisdictions. http://www,fincen.gov • Countries in which the production or transportation of illegal drugs may be taking place. • Bank secrecy havens such as Cayman Islands. • Emerging countries that may be seeking hard currency investments. • Countries identified in FinCEN advisories. • Major money laundering countries and jurisdictions.
For Training Purposes Only
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