Introductory BSA AML Examiner School Manual Palm Springs 2019

MSBs Can Help Fight Money Laundering

What Should MSBs Look For? Money laundering schemes can vary widely. Federal action to curtail money laundering activities once focused heavily on identification and documentation of large currency transactions. More recently, anti-money laundering efforts have focused on the use of money transfers, both through bank and non- bank money transfer systems, and other means of moving funds. Today, as money launderers become more sophisticated, all types of financial transactions are facing greater scrutiny. The following situations may indicate money laundering or other illegal activity. These lists are not comprehensive, but they may help MSBs recognize ways launderers and other criminals may try to use them to launder money.

Multiple Persons or Locations Two or more customers working together to break one transaction into two or more transactions in order to evade the BSA reporting or recordkeeping requirement. break one transaction into smaller transactions and evade the BSA reporting or recordkeeping requirement. Overt Illegal Customer Conduct Customer offers bribes or tips. Customer admits to criminal conduct. An MSB that correctly verifies and documents a customer’s identity is more likely to recognize suspicious activity that should be reported. ■ ■ ■ ■ Customer uses two or more locations or cashiers in the same day in order to

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