Introductory BSA/AML Examiner School, Atlanta, CA

MSBs Can Help Fight Money Laundering

Red Flags When a single factor signals that a transaction is unusual and possibly “suspicious,” it is called a “red flag.” Examples of Some Common Red Flags:

regularly using an Internet auction site to buy and sell antique jewelry.

What is a transaction that “Involves Use of the MSB to Facilitate Criminal Activity?” Example. An MSB suspects that a custom- er is sending a money transfer in order to fund a terrorist organization. It is important to note that size alone, such as a large cash transaction or money transfer, should not be a determining factor in the decision to file a SAR. Factors that should contribute to that decision, however, include the following: the size, frequency and nature of the transactions; the MSB’s experience with the customer and other individuals or entities associated with the transaction (if any); and the norm for such transactions within the MSB’s line of business and geographic area.

Customer ID or Information Customer uses false ID.

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Two/more customers use similar IDs. Customer alters transaction upon learning that he/she must show ID. Customer alters spelling or order of his/her full name. Transactions Below Reporting or Recordkeeping Thresholds Customer conducts transactions just below relevant thresholds: ■

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Currency exchanges just under $1,000. Cash sales of money orders or traveler’s checks of just under $3,000.

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