Guide to U.S. Anti-Money Laundering Requirements. Fourth Edition

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1 Guide t U.S. Anti-Mney Laundering Requirements Furth Editin

2 PREFACE Prtiviti is pleased t publish this furth versin f its Guide t U.S. Anti-Mney Laundering Requirements. As with the first three editins f the Guide, this 2010 editin cntains questins that have surfaced in ur discussins with clients, attrneys, regulatrs and thers, bth in the United States and ther markets. The number f questins and answers has been expanded frm the previus versin. Amng the new infrmatin included are questins and answers related t rules and regulatry requirements issued in the past tw years, as well as expanded discussins n a number f tpics, including risk assessments, anti-mney laundering (AML) and sanctin cmpliance technlgy, and internatinal perspectives and initiatives. The Guide begins by addressing the majr AML and sanctin cmpliance requirements in the United States, namely the Bank Secrecy Act (BSA), the USA PATRIOT Act and the Office f Freign Assets Cntrl (OFAC) requirements. This is fllwed by sectins n Knw Yur Custmer, Risk Assessments, (including expanded discussin f high-risk custmers), Transactin Mnitring and Investigatins, Third-Party Reliance, AML Technlgy, Nnbank Financial Institutins and Nnfinancial Businesses, Cnvergence f AML with Fraud and Other Regulatry Tpics, and Internatinal Perspectives and Initiatives. Als included in the resurce sectins at the back f the Guide are website addresses fr sme f the surces used t develp the questins and answers, a glssary f useful acrnyms, and a listing f key AML laws and regulatins. Althugh the fcus f the Guide is n U.S. requirements, we have included sme highlights f multilateral requirements and believe the Guide is instructive t cmpanies utside f the United States because f the cnvergence f AML requirements and industry best practices acrss the glbe. It is imprtant t nte that this Guide is prvided fr general infrmatin nly and fcuses primarily n federal AML requirements; it is nt intended t be legal analysis r advice, nr des it purprt t address, except in a few instances, state r internatinal mney laundering requirements that may affect U.S. cmpanies. Cmpanies shuld seek the advice f legal cunsel r ther apprpriate advisers n specific questins as they relate t their unique circumstances. The develpment and maintenance f effective AML Cmpliance Prgrams remain dynamic. Accrdingly, we expect that many f the respnses included in this bklet will cntinue t evlve. Prtiviti Inc. Octber 2010 Acknwledgements This bklet was develped thrugh the cllabrative effrt f Prtiviti s AML team, particularly Daniel Haggerty and Kaitlin Lemm, and ur clleague and frmer assciate Karen L. Wilkes. The Prtiviti AML team extends special thanks t Debrah Thren-Peden f Pillsbury Winthrp Shaw Pittman LLP, wh served as a reviewer. 1

3 CONTENTS AT A GLANCE TABLE OF CONTENTS... 3 ANTI-MONEY LAUNDERING FUNDAMENTALS... 9 BANK SECRECY ACT USA PATRIOT ACT OFFICE OF FOREIGN ASSETS CONTROL AND INTERNATIONAL GOVERNMENT SANCTIONS PROGRAMS KNOW YOUR CUSTOMER, CUSTOMER DUE DILIGENCE AND ENHANCED DUE DILIGENCE RISK ASSESSMENTS TRANSACTION MONITORING, INVESTIGATIONS AND RED FLAGS AML TECHNOLOGY NONBANK FINANCIAL INSTITUTIONS AND NONFINANCIAL BUSINESSES CONVERGENCE OF AML WITH FRAUD AND OTHER REGULATORY TOPICS INTERNATIONAL PERSPECTIVES AND INITIATIVES ACRONYMS AND GLOSSARY KEY U.S. AML LAWS AND REGULATIONS AND USEFUL WEBSITES ABOUT PROTIVITI

4 TABLE OF CONTENTS ANTI-MONEY LAUNDERING FUNDAMENTALS... 9 Key Definitins... 9 Overview f U.S. AML Laws and Regulatins Overview f the U.S. Regulatry Framewrk Key U.S. Regulatry Authrities and Law Enfrcement Agencies Financial Crimes Enfrcement Netwrk Enfrcement Actins AML Cmpliance Prgram BANK SECRECY ACT Overview f BSA Reprting Requirements Currency Transactin Reprts CTR Basics CTR Threshld and Aggregatin Cmpletin f a CTR Frm CTR Exemptins CTR Evasin CTR Trends Suspicius Activity Reprts SAR Basics SAR Filing Time Frame and Date f Initial Detectin Cmpletin f a SAR Frm Cnfidentiality Jint Filings f SARs Safe Harbr Mnitring and Terminating Relatinships with SAR Subjects Law Enfrcement SAR Trends Frm Frm 8300 Basics Ntificatin Filing f Frm Reprting Suspicius Activity n Frm Reprt f Freign Bank and Financial Accunts FBAR Basics FBAR Filing Recent Tax Scandals FBAR Prpsals Reprt f Internatinal Transprtatin f Currency r Mnetary Instruments

5 CMIR Basics CMIR Filing Recrdkeeping Requirements Funds Transfer Recrdkeeping Requirement and the Travel Rule Funds Transfer Recrdkeeping Requirement and the Travel Rule Basics Addresses and Abbreviatins Verificatin f Identity Jint Party Transmittals and Aggregatin Retrievability Crss-Brder Electrnic Transmittal f Funds Recrdkeeping Requirements fr the Purchase and Sale f Mnetary Instruments USA PATRIOT ACT Overview f the USA PATRIOT Act USA PATRIOT Act Analysis f Key Sectins Sectin 311 Special Measures Sectin 312 Special Due Diligence fr Crrespndent Accunts and Private Banking Accunts.. 75 Overview Due Diligence fr Crrespndent Accunts Enhanced Due Diligence fr Crrespndent Accunts Due Diligence fr Private Banking Accunts Enhanced Due Diligence fr Private Banking Accunts Senir Freign Plitical Figure Sectin 313 Prhibitin n U.S. Crrespndent Accunts with Freign Shell Banks Sectin 314 Cperative Effrts t Deter Mney Laundering Sectin 314(a) Cperatin amng Financial Institutins, Regulatry Authrities and Law Enfrcement Authrities Sectin 314(b) Cperatin amng Financial Institutins Sectin Frfeiture f Funds in U.S. Interbank Accunts Sectin 319(a) Requirements Frfeiture frm U.S. Interbank Accunts Sectin 319(b) Requirements Bank Recrds Dmestic Financial Institutin Recrds ( 120-Hur Rule ) Freign Bank Recrds Freign Bank Certificatins Sectin 325 Cncentratin Accunts at Financial Institutins Sectin 326 Verificatin f Identificatin Overview Custmer Defined Accunt Defined Verificatin Updating CIP fr Existing Custmers Recrd Retentin List Matching Custmer Ntice Third-Party Reliance Sectin 352 AML Prgram Overview Plicies and Prcedures Designatin f AML Cmpliance Officer and the AML Cmpliance Organizatin AML Training Independent Testing Sectin 505 Miscellaneus Natinal Security Authrities

6 OFFICE OF FOREIGN ASSETS CONTROL AND INTERNATIONAL GOVERNMENT SANCTIONS PROGRAMS OFAC Basics Specially Designated Natinals and Blcked Persns List Cuntry- and Regime-Based Sanctins Prgrams Nn-Specially Designated Natinals Palestinian Cuncil List U-Turn Payments Cmprehensive Iran Sanctins, Accuntability, and Divestment Act f 2010 (CISADA) Screening Custmers and Transactins Autmated Clearing Huse Transactins and IATs Trade Finance Transactins Blcking and Rejecting Transactins Investigating Ptential Matches Reprting Requirements Blcked/Rejected Transactin Reprts Licensing Letter and Prepenalty Ntice Vluntary Disclsure Independent Testing Cnsequences f Nncmpliance Cmmn Gaps and Challenges Other U.S. and Internatinal Gvernment Sanctins Prgrams KNOW YOUR CUSTOMER, CUSTOMER DUE DILIGENCE AND ENHANCED DUE DILIGENCE Overview Updating Custmer Due Diligence and Enhanced Due Diligence Beneficial Owners Knw Yur Emplyee Knw Yur Third Parties RISK ASSESSMENTS Overview Business Line Risk Assessment Custmer Risk Assessment High-Risk Gegraphies High-Risk Custmers Nnresident Aliens and Freign Persns Prfessinal Service Prviders Trust and Asset Management Services Depsit Brker Private Banking Plitically Expsed Persns Freign Embassy and Cnsulates Business Entities: Shell Cmpanies, Private Investment Cmpanies

7 Crrespndent Banking Nnbank Financial Institutins Charitable Organizatins and Nngvernmental Organizatins Third-Party Payment Prcessrs Privately Owned Autmated Teller Machines (ATMs) High-Risk Prducts, Services and Transactins Currency Transactins Bulk Shipments f Currency Funds Transfers Autmated Clearing Huse Transactins Mnetary Instruments U.S. Dllar Drafts Puch Activity Payable Thrugh Accunts Cncentratin Accunts Electrnic Banking Online Banking Autmated Teller Machines Remte Depsit Capture Prepaid Access, Stred-Value and E-Cash Expanding the Definitin f Stred Value Trade Finance Activities Lending Activities Nndepsit Investment Prducts Insurance Prducts Administratin f Custmer Risk Assessment Office f Freign Assets Cntrl Risk Assessment TRANSACTION MONITORING, INVESTIGATIONS AND RED FLAGS Mnitring Prcess Rles and Respnsibilities Investigatin Prcess Suspicius Activity Red Flags Accunt Opening Red Flags Accunt Activity and Transactin Executin Red Flags Currency Red Flags Privately Owned ATM Red Flags Bulk Shipments f Currency Red Flags Branch and Vault Shipments Red Flags Mnetary Instrument Red Flags U.S. Dllar Draft Red Flags Wire Transfer Red Flags Certificate f Depsit Red Flags Safe Depsit Bx Red Flags Lending Red Flags Mrtgage and Real Estate Red Flags Credit Card Red Flags Trade Finance Red Flags Capital Market Prducts Red Flags Insurance Prducts Red Flags Casin Red Flags Retail Red Flags Cnsumer Prducts Red Flags

8 Infrmal Value Transfer System (IVTS) Red Flags Terrrist Financing Red Flags Emplyee Red Flags AML TECHNOLOGY Overview Suspicius Transactin Mnitring and Suspicius Activity Reprt Filing Sftware Case Management Sftware Large Currency Transactin Mnitring and Currency Transactin Reprt Filing Sftware Custmer Infrmatin Database and Custmer Risk Assessment Sftware Custmer Verificatin Sftware List Prviders Interdictin Sftware Training Sftware NONBANK FINANCIAL INSTITUTIONS AND NONFINANCIAL BUSINESSES Nnbank Financial Institutins Mney Services Businesses Definitin Issuers and Redeemers f Mnetary Instruments Check Cashers Currency Dealers r Exchangers Stred Value Mney Transmitters Guidance n the Applicability f the Definitin f Mney Services Businesses Key AML Requirements Registratin Agents Infrmal Value Transfer Systems Definitin Black Market Pes Exchange Reintegr Brker-Dealers Definitin Key AML requirements Futures Cmmissin Merchants and Intrducing Brkers Definitin Key AML Requirements Cmmdity Trading Advisers and Cmmdity Pl Operatrs Definitin Key AML Requirements Mutual Funds Definitin Key AML Requirements Insurance Cmpanies Definitin Key AML Requirements Casins r Card Clubs Definitin Key AML Requirements Operatrs f Credit Card Systems

9 Definitin Key AML Requirements Dealers in Precius Metals, Stnes r Jewels Definitin Key AML Requirements Persns Invlved in Real Estate Settlements and Clsings Definitin Key AML Requirements Investment Advisers Definitin Key AML Requirements Unregistered Investment Cmpanies Definitin Key AML Requirements Ntice Nnfinancial Businesses Definitin Key AML Requirements CONVERGENCE OF AML WITH FRAUD AND OTHER REGULATORY TOPICS AML and Anti-Fraud Prgrams CIP vs. Identity Theft Preventin Prgram Mrtgage Fraud Unlawful Internet Gambling Enfrcement Act and Prhibitin n Funding f Unlawful Internet Gambling Regulatin INTERNATIONAL PERSPECTIVES AND INITIATIVES Internatinal Perspectives Key Internatinal Grups and Initiatives Financial Actin Task Frce FATF Basics Members and Observers Analysis f Frty Recmmendatins and Nine Special Recmmendatins Definitins Frty Recmmendatins Nine Special Recmmendatins Nn-Cperative Cuntries and Territries and High-Risk Jurisdictins Mutual Evaluatins ACRONYMS AND GLOSSARY KEY U.S. AML LAWS AND REGULATIONS AND USEFUL WEBSITES ABOUT PROTIVITI

10 ANTI-MONEY LAUNDERING FUNDAMENTALS Key Definitins 1. What is mney laundering? Mney laundering is the attempt t disguise the prceeds f illegal activity s that they appear t cme frm legitimate surces r activities. 2. Hw des mney laundering wrk? Mney laundering can and des take many frms. It typically ccurs in three stages: placement, layering and integratin. Placement is the stage in which funds derived frm illegal activities are intrduced int the financial system anywhere in the wrld. Layering invlves cnducting ne r mre transactins designed t disguise the audit trail and make it mre difficult t identify the initial surce f funds. Integratin is the stage in which the funds are disbursed back t the mney launderer in what appear t be legitimate transactins. 3. What types f crimes may give rise t a charge f mney laundering? Althugh mney laundering is ften equated with drug trafficking, the prceeds f many crimes can be assciated with mney laundering. These include, but are nt limited t, financial fraud, tax evasin, cmputer crimes, alien smuggling, illegal arms sales, freign fficial crruptin, exchange cntrl vilatins, illegal gambling and terrrist financing. 4. What is the current scale f the mney laundering prblem? Measuring the current scale f mney laundering is extremely difficult. Ntwithstanding the attempts f many rganizatins and academics t estimate the vlume f mney laundering, ne f the mst cited measurements, thugh it is smewhat dated, was develped by the Internatinal Mnetary Fund (IMF), which estimated the vlume f mney laundering t be between 2 and 5 percent f glbal grss dmestic prduct (GDP), equivalent t apprximately $590 billin t $1.5 trillin annually. While this range may still be the best estimate, there have been suggestins that certain reginal and glbal trends, such as the increase in trade with the expansin f the Eurpean Unin (EU), are cntributing t an increase in the vlume f mney laundering. 5. What is terrrism? Terrrism is ften defined as an activity that invlves a vilent act r an act dangerus t human life, prperty r infrastructure that appears t be intended t: Intimidate r cerce a civilian ppulatin Influence the plicy f a gvernment by intimidatin r cercin Affect the cnduct f a gvernment by mass destructin, assassinatin, kidnapping r hstage taking 9

11 6. What is terrrist financing? Terrrist financing is a financial crime that uses funds t supprt the agenda, activities r cause f a terrrist rganizatin. The funds raised may be frm legitimate surces, such as charitable rganizatins r dnatins frm supprters, as well as criminal surces, such as drug trade, weapns smuggling, fraud, kidnapping and extrtin fr illegal activities. 7. What is the difference between mney laundering and terrrist financing? In cntrast t mney laundering, which invlves the disguising f funds derived frm illegal activity s they may be used withut detectin f the illegal activity, terrrist financing can invlve the use f legally derived mney t carry ut illegal activities. The bjective f mney laundering is financial gain r the hiding r disguising f illicit prceeds, whereas with terrrism, the bjective is t prmte the agenda r cause f the terrrist rganizatin. Fr example, it is widely believed that the terrrist activities f September 11, 2001, were partially financed by legally btained funds that had been dnated t charities. Bth mney launderers and terrrists, hwever, d need t disguise the assciatin between themselves and their funding surces. 8. Is the apprach t cmbat mney laundering and terrrist financing the same? Althugh sme f the risk factrs and red flags that apply t ther types f mney laundering als may apply t terrrist financing, the patterns f activity tend t be very different. Terrrist financing ften invlves very small amunts f funds, which may be mved thrugh charities r nntraditinal banking systems, whereas ther types f mney laundering may invlve large vlumes f funds. It is imprtant t understand the different patterns t prtect against the risks. Overview f U.S. AML Laws and Regulatins 9. What are the key U.S. AML laws and regulatins? The key U.S. AML laws and regulatins are the Bank Secrecy Act f 1970 (BSA) and the Uniting and Strengthening America by Prviding Apprpriate Tls Required t Intercept and Obstruct Terrrism Act f 2001 (cmmnly referred t as the USA PATRIOT Act). The BSA was the first majr mney laundering legislatin in the United States. It was designed t deter the use f secret freign bank accunts and prvide an audit trail fr law enfrcement by establishing regulatry reprting and recrdkeeping requirements t help identify the surce, vlume and mvement f currency and mnetary instruments int r ut f the United States r depsited in financial institutins. Fr additinal guidance n the Bank Secrecy Act, please refer t the Bank Secrecy Act sectin. The USA PATRIOT Act was signed int law by President Gerge W. Bush n Octber 26, 2001, fllwing the terrrist activity f September 11. Title III, the Internatinal Mney Laundering Abatement and Anti-Terrrist Financing Act f 2001, deals with mney laundering and terrrist financing. Title III made significant changes t mney laundering regulatins, impsed enhanced requirements fr AML prgrams, and significantly expanded the scpe f cverage t nnbank financial institutins. It requires financial institutins t establish AML prgrams that include plicies, prcedures and cntrls, designatin f a cmpliance fficer, training, and independent review. It als requires, amng ther things, that certain financial institutins establish custmer identificatin prcedures fr new accunts as well as enhanced due diligence (EDD) fr crrespndent and private banking accunts maintained by nn-u.s. persns. Fr additinal guidance n the USA PATRIOT Act, please refer t the USA PATRIOT Act sectin. 10. What ther AML laws have been enacted in the United States? In additin t the BSA and Title III f the USA PATRIOT Act, ther AML laws include the Mney Laundering Cntrl Act f 1986 (MLCA), the Anti-Drug Abuse Act f 1988, the Annunzi-Wylie Anti-Mney Laundering Act f 1992, the Mney Laundering Suppressin Act f 1994 (MLSA), and the Mney Laundering and Financial Crimes Strategy Act f The MLCA established tw AML criminal statutes that, fr the first time, made mney laundering a criminal ffense, with penalties f up t 20 years and fines f up t $500,000 fr each cunt. Additinally, the MLCA prhibits the structuring f currency transactins t avid filing requirements and requires financial institutins t develp BSA cmpliance prgrams. 10

12 The primary purpse f the Anti-Drug Abuse Act f 1988 was t prvide funding and technical assistance t state and lcal units f gvernment t cmbat crime and drug abuse. This Act increased the civil and criminal penalties fr mney laundering and ther BSA vilatins t include frfeiture f any prperty r asset invlved in an illegal transactin related t mney laundering. It als intrduced the sting prvisin, which enables law enfrcement t represent the surce f funds invlved in a transactin as the prceeds f unlawful activity. This Act als required the identificatin and recrding f purchases f mnetary instruments, including bank checks r drafts, freign drafts, cashier s checks, mney rders r traveler s checks in amunts between $3,000 and $10,000 inclusive. This legislatin, in cnjunctin with the Office f Natinal Drug Cntrl Plicy (ONDCP) Reauthrizatin Act f 1998, authrized the Directr f the ONDCP t designate areas within the United States that exhibit serius drug trafficking prblems and harmfully impact ther areas f the cuntry as High Intensity Drug Trafficking Areas (HIDTAs). The HIDTA prgram aims t imprve the effectiveness and efficiency f drug cntrl effrts amng lcal, state and federal law enfrcement agencies. The Annunzi-Wylie Anti-Mney Laundering Act f 1992 gave prtectin frm civil liability t any financial institutin, r directr, fficer r emplyee theref, wh/that makes a Suspicius Activity Reprt (SAR) under any lcal, state r federal law. The Annunzi-Wylie Act made it illegal t disclse when a SAR is filed. It als made it illegal t perate a mney transmitting business withut a license where such a license is required under state law, and required all financial institutins t maintain recrds f dmestic and internatinal funds transfers. In additin, this Act intrduced the death penalty, mandating that bank regulatrs cnsider taking actin t revke the charter f any banking rganizatin that is fund guilty r pleads guilty t a charge f mney laundering. The Mney Laundering Suppressin Act f 1994 (MLSA) specifically addressed mney services businesses (MSBs), requiring each MSB t register and maintain a list f its agents. In additin t making it a federal crime t perate an unregistered MSB, the MLSA encuraged states t adpt unifrm laws applicable t MSBs. It als established prcedures that allwed banks t exempt certain custmers frm Currency Transactin Reprt (CTR) filing. Cntinuing with the trend f develping a natinal strategy t cmbat mney laundering, the Mney Laundering and Financial Crimes Strategy Act f 1998 called fr the designatin f areas at high-risk fr mney laundering and related financial crimes by gegraphy, industry, sectr r institutin. Sme f these areas were later designated as High Risk Mney Laundering and Related Financial Crimes Areas (HIFCAs). The HIFCA prgram was created t crdinate the effrts f lcal, state and federal law enfrcement agencies in the fight against mney laundering. The Intelligence Refrm and Terrrism Preventin Act f 2004 amended the BSA t require the U.S. Treasury Secretary t prescribe regulatins requiring certain financial institutins t reprt crss-brder electrnic transmittals f funds, if the Secretary determines such reprting is reasnably necessary t aid in the fight against mney laundering and terrrist financing. 11. What is the rle f the Office f Freign Assets Cntrl (OFAC) and hw des it fit int AML laws and regulatins? The purpse f OFAC is t prmulgate, administer and enfrce ecnmic and trade sanctins against certain individuals, entities and freign gvernment agencies and cuntries whse interests are cnsidered t be at dds with U.S. plicy. Sanctins prgrams target, fr example, terrrists and terrrist natins, drug traffickers and thse engaged in the prliferatin f weapns f mass destructin. Overviews and details f the OFAC Sanctins prgrams can be fund n OFAC s website at OFAC regulatins are nt part f AML cmpliance per se, but since the OFAC Sanctins lists include alleged mney launderers and terrrists and USA PATRIOT Act requirements mandate that certain financial institutins vet custmer names against the OFAC list, institutins ften cnsider the OFAC prgram t be a subset f their verall AML prgram. Fr additinal guidance, please refer t the Office f Freign Assets Cntrl and Internatinal Gvernment Sanctins Prgrams sectin. 12. Hw can ne measure the effectiveness f an AML regime? A number f factrs can be cnsidered when assessing the effectiveness f an AML regime, including the number f mney laundering/terrrist financing investigatins, prsecutins and cnvictins, number and amunt f frzen/seized assets, identificatin f deficiencies in financial institutins in examinatins by regulatry authrities, and quality f crdinatin amng financial institutins, regulatry and law enfrcement authrities. Fr additinal guidance n tls and techniques used t assess the effectiveness f AML systems, please refer t the Financial Actin Task Frce sectin. 11

13 13. Hw d U.S. regulatins cmpare t internatinal AML regulatins? As a result f the terrrist activities f September 11, 2001, the U.S. strengthened its AML regulatins significantly. The USA PATRIOT Act expanded the traditinal definitin f a financial institutin. It was bradened t encmpass numerus businesses that previusly were nt subject t AML regulatins. Fr example, U.S. AML regulatins apply t, amng thers, casins and dealers in precius metals and jewelry, which were previusly unregulated businesses. The USA PATRIOT Act als required sweeping measures t be taken with respect t shell banks and crrespndent accunts. While these measures may nt have been incrprated previusly int ther cuntries AML standards, the cntinued internatinal fcus n AML standards has encuraged many cuntries t intrduce several new AML regulatins, which, in large part, already have been implemented in the United States because f the USA PATRIOT Act. Unlike Australia and the United Kingdm, the United States has nt implemented regulatins fr select prfessinal service prviders (e.g., attrneys, accuntants). In fact, the Financial Actin Task Frce (FATF), in its mst recent assessment f the United States anti-mney laundering regime, identified several areas in need f imprvement, including: custmer due diligence relating t beneficial wners, authrized signers, legal persns and trusts; nging due diligence; and general requirements fr designated nnfinancial businesses and prfessins (DNFBPs) (e.g., casins, accuntants, attrneys, dealers in precius metals and stnes, and real estate agents). Fr additinal guidance, please refer t the Financial Actin Task Frce and Mutual Evaluatin Reprts sectins. Fr additinal guidance n internatinal perspectives, please refer t the Internatinal Perspectives and Initiatives sectin. 14. What are the cnsequences f nt cmplying with AML laws and regulatins? The cnsequences f nncmpliance with AML laws and regulatins may include regulatry enfrcement actins, civil and criminal penalties, seizure and frfeiture f funds, and incarceratin fr the individuals invlved. Depsitry institutins als may be subject t restrictins n grwth and expansin and, in the extreme, may have their charters/licenses revked, a cnsequence knwn as the death penalty. Fr additinal guidance, please refer t the Enfrcement Actins sectin. 15. What factrs are cnsidered by law enfrcement when it assesses whether an institutin r its persnnel are guilty f aiding and abetting mney laundering r terrrist financing? When assessing whether an institutin r its persnnel are guilty f aiding and abetting mney laundering r terrrist financing, the authrities cnsider, amng ther factrs, the fllwing standards f knwledge : Reckless Disregard Careless disregard fr legal r regulatry requirements and sund business practice Willful Blindness Deliberate ignrance and failure t fllw up in the face f infrmatin that suggests prbable mney laundering r illicit activity Cllective Knwledge Aggregates/attributes the knwledge f emplyees t the emplying cmpany It is imprtant t remember that under U.S. law, a cmpany may, in general, be held liable fr the actins f its emplyees, regardless f the number r level f emplyees invlved in the wrngding. 12

14 Overview f the U.S. Regulatry Framewrk Key U.S. Regulatry Authrities and Law Enfrcement Agencies 16. Wh has the authrity t assess penalties fr vilatins f AML laws and regulatins? Authrity t assess civil penalties rests with the Secretary f the Treasury and is delegated t the Financial Crimes Enfrcement Netwrk (FinCEN) and the primary federal regulatrs r Self-Regulatry Organizatins (SROs) (e.g., Financial Industry Regulatry Authrity [FINRA], U.S. Securities and Exchange Cmmissin [SEC]). Sme state regulatry agencies have their wn authrity t assess civil penalties, as well. Criminal penalties are determined thrugh legal prceedings at state r federal levels. The Department f Justice (DOJ) can bring criminal and civil actins, as well as frfeiture actins. 17. Wh are the primary federal banking regulatrs and what are their respnsibilities? The five federal banking regulatrs include: The Bard f Gvernrs f the Federal Reserve System (FRB) versees state-chartered banks and trust cmpanies that belng t the Federal Reserve System. The Federal Depsit Insurance Crpratin (FDIC) regulates federally charted banks (e.g., state-chartered banks that d nt belng t the Federal Reserve System). The Office f the Cmptrller f the Currency (OCC) regulates federally chartered banks (e.g., banks that have the wrd Natinal in r the letters N.A. after their names. The Natinal Credit Unin Administratin (NCUA) regulates federally chartered credit unins. The Office f Thrift Supervisin (OTS) versees federal savings and lans and federal savings banks. (As a result f the Wall Street Refrm and Cnsumer Prtectin Act, knwn as the Ddd-Frank Act, the OTS will be disslved and its supervisry respnsibilities will be transferred t the FRB, OCC and FDIC.) Other regulatry bdies were authrized by the Ddd-Frank Act, but their mandates deal mre specifically with brad prudential cnsideratins and cnsumer prtectin. 18. What is the Federal Financial Institutins Examinatin Cuncil (FFIEC)? The Federal Financial Institutins Examinatin Cuncil (FFIEC) is a frmal interagency bdy empwered t prescribe unifrm principles, standards and reprt frms, and t make recmmendatins t prmte unifrmity in the supervisin f financial institutins. Cuncil members include the five federal regulatrs: FRB, FDIC, OCC, NCUA, OTS and the State Liaisn Cmmittee (SLC). The SLC includes representatives frm the Cnference f State Bank Supervisrs (CSBS), the American Cuncil f State Savings Supervisrs (ACSSS), and the Natinal Assciatin f State Credit Unin Supervisrs (NASCUS). 19. Wh are the key nnbanking regulatry agencies? Nnbanking regulatry agencies include but are nt limited t: Securities and Exchange Cmmissin (SEC): The SEC is the federal regulatr f the securities markets and administers the federal securities laws (including the Securities Act f 1933, the Securities Exchange Act f 1934, the Investment Cmpany Act f 1940, the Investment Advisers Act f 1940 and the Trust Indenture Act f 1939), with direct regulatry and versight respnsibilities f securities exchanges, securities brkers and dealers, investment advisers and investment cmpanies, and self-regulatry rganizatins (SROs). Cmmdity Futures Trading Cmmissin (CFTC): The CFTC is the federal regulatr f U.S. cmmdity futures and ptins markets in the United States. It administers and enfrces the federal futures and ptins laws as set frth in the Cmmdity Exchange Act (CEA) and the accmpanying regulatins. Financial Industry Regulatry Authrity (FINRA): Frmerly knwn as the Natinal Assciatin f Securities Dealers (NASD), FINRA is an SRO fr brker-dealers. 13

15 Natinal Futures Assciatin (NFA): The NFA is the SRO fr the futures market. New Yrk Stck Exchange (NYSE): The NYSE is the SRO fr exchange member rganizatins (i.e., registered brker-dealer rganized as a crpratin, a partnership r an LLC that hlds an NYSE trading license r pts fr NYSE regulatin). Natinal Indian Gaming Cmmissin (NIGC): The NIGC is an independent federal regulatry agency whse primary missin is t regulate gaming activities n Indian lands. IRS Tax Exempt and Gvernment Entities Divisin (IRS-TEGE): The IRS-TEGE prvides federal versight t all nnprfit rganizatins in the United States, including reviews t determine if nnprfit rganizatins are facilitating terrrist financing. IRS Small Business and Self-Emplyment Divisin (IRS-SBSE): The IRS-SBSE has been delegated examinatin authrity ver all financial institutins that d nt have a federal functinal regulatr as defined in the BSA, including MSBs, insurance cmpanies, credit card cmpanies, nnfederally insured credit unins, casins (tribal and nntribal), and dealers in precius metals, stnes and jewels. The IRS-SBSE als has respnsibility fr auditing cmpliance with currency transactin reprting requirements that apply t any trade r business (Frm 8300). Fr further guidance n the AML respnsibilities f brker-dealers, mney services businesses and ther nnbank entities, please refer t the Nnbank Financial Institutins and Nnfinancial Business sectin. 20. What are the key law enfrcement agencies respnsible fr cmbating mney laundering and terrrist financing? Key law enfrcement agencies respnsible fr cmbating mney laundering and terrrist financing include: Drug Enfrcement Administratin (DEA) Federal Bureau f Investigatin (FBI) Department f Hmeland Security, Immigratin and Custms Enfrcement (ICE) Department f Hmeland Security, Custms and Brder Prtectin (CBP) Internal Revenue Service Criminal Investigatin (IRS-CI) 21. What are examples f ther key agencies with respnsibilities t cmbat mney laundering and terrrist financing? Key agencies with respnsibilities t establish plicies and strategies t cmbat mney laundering and terrrist financing include, but are nt limited t, the fllwing: U.S. Department f the Treasury Office f Terrrism and Financial Intelligence (TFI) Office f Terrrist Financing and Financial Crime (TFFC) Office f Intelligence and Analysis (OIA-T) Financial Crimes Enfrcement Netwrk (FinCEN) Office f Freign Assets Cntrl (OFAC) Treasury Executive Office fr Asset Frfeiture (TEOAF) U.S. Department f Justice (DOJ) Asset Frfeiture and Mney Laundering Sectin, Criminal Divisin (AFMLS) Cunterterrrism Sectin, Criminal Divisin (CTS) Natinal Drug Intelligence Center (NDIC) Office f Internatinal Affairs, Criminal Divisin (OIA) 14

16 U.S. State Department Bureau f Ecnmic and Business Affairs (EB) Bureau f Internatinal Narctics and Law Enfrcement Affairs (INL) State s Office f the Crdinatr fr Cunterterrrism (S/CT) 22. What publicatins and resurces have been prvided t the public by U.S. regulatry and/r law enfrcement authrities? Examples f publicatins and resurces include, but are nt limited t, the fllwing: FFIEC Bank Secrecy Act/Anti-Mney Laundering Examinatin Handbk Prvides guidance t examiners fr carrying ut BSA/AML and OFAC examinatins fr depsitry institutins. The manual cntains an verview f AML Cmpliance Prgram requirements, AML risks (e.g., prducts, services, transactins and custmer types f heightened risk), risk management expectatins, industry sund practices and examinatin prcedures. The develpment f this manual was a cllabrative effrt f the Federal Reserve, the OCC, the NCUA, the OTS, the FDIC and FinCEN t ensure cnsistency in the applicatin f AML requirements. Bank Secrecy Act/Anti-Mney Laundering Examinatin Manual fr Mney Services Businesses Prvides guidance t examiners fr carrying ut BSA/AML and OFAC examinatins fr MSBs. The manual cntains an verview f AML Cmpliance Prgram requirements, risk management expectatins, industry sund practices, examinatin prcedures, verviews f the different types f MSBs (i.e., check cashers, currency dealers r exchangers, issuers f traveler s checks and mney rders, mney transmitters), verview f the relatinship between principals and agents, and additinal guidance n MSB registratin requirements, freign agent r freign cunterparty due diligence, and recrdkeeping and retentin requirements fr all types f MSBs. The develpment f this manual was a cllabrative effrt by the IRS, state agencies respnsible fr MSB regulatins, the Mney Transmitter Regulatrs Assciatin (MTRA), the Cnference f State Bank Supervisrs (CSBS), and FinCEN. Bank Secrecy Act Exam Resurces Develped by the NCUA, this publicatin prvides guidance t examiners fr carrying ut AML and OFAC examinatins fr credit unins. FFIEC Infrmatin Technlgy Examinatin Handbk Develped thrugh a cllabrative effrt f the Federal Reserve, the OCC, the NCUA, the OTS and the FDIC, the IT Examinatin Handbk cvers key technlgy tpics as they relate t financial services in separate bklets, including: Audit Operatins Management Business cntinuity planning Outsurcing technlgy services Develpment and acquisitin Retail payment systems Whlesale payment systems E-banking supervisin f technlgy service prviders Infrmatin security The IT Examinatin Handbk prvides guidance n tpics such as risks and suggested cntrls n third-party payment prcessrs (e.g., Autmated Clearing Huse (ACH) prviders, remte depsit capture (RDC) prviders) and electrnic payments (e.g., electrnic banking, autmated teller machine [ATM]). Anti-Mney Laundering (AML) Surce Tl fr Brker-Dealers Develped by the SEC t assist brkerdealers with fulfilling their respnsibilities t establish an AML Cmpliance Prgram, as required by AML laws and regulatins. Template fr Small Firms This template, available n FINRA s website, is designed t assist small firms in fulfilling their respnsibilities t establish an AML Cmpliance Prgram, as required by the BSA and its 15

17 implementing regulatins and FINRA Rule 3310, by prviding text examples, instructins, relevant rules, websites and ther resurces. Cmpliance Self-Assessment Guide Develped by the NCUA, this guide is intended fr use by a credit unin s bard f directrs and management, cmpliance fficers, and thers having respnsibility fr cmpliance as part f their duties. While the guide cvers mst federal cnsumer prtectin laws and regulatins that affect credit unins, it des nt address all federal laws r any state laws. AML e-learning curses FINRA ffers several e-learning curses and interactive scenaris n AML-related tpics, ranging frm custmer identificatin prcedures t recgnizing red flags. U.S. Mney Laundering Threat Assessment (MLTA) Published in 2005, the MLTA was written by the fllwing agencies, bureaus and ffices: Office f Terrrist Financing and Financial Crime (TFFC) Financial Crimes Enfrcement Netwrk (FinCEN) Office f Intelligence and Analysis (OIA) Office f Freign Assets Cntrl (OFAC) Executive Office fr Asset Frfeiture (TEOAF) Internal Revenue Service (IRS) Criminal Investigatin (CI) IRS Small Business/Self-Emplyed Divisin (SB/SE) Federal Bureau f Investigatin (FBI) Drug Enfrcement Administratin (DEA) Asset Frfeiture Mney Laundering Sectin (AFMLS) Natinal Drug Intelligence Center (NDIC) Organized Crime Drug Enfrcement Task Frce (OCDETF) Immigratin and Custms Enfrcement (ICE) Custms and Brder Prtectin (CBP) Federal Reserve United States Pstal Inspectin Service (USPIS) The MLTA cntains detailed analyses f mney laundering vulnerabilities acrss banking, insurance, casins and MSBs including, but nt limited t, the fllwing: Banking (e.g., crrespndent banking, cash letters/puch activities, private banking, nline banking, remte depsit capture [RDC]) MSBs (e.g., prvisin f check cashing, mney transmissin, stred value, mnetary instrument, currency exchange services t nncustmers ) and infrmal value transfer systems (IVTS) Emerging electrnic and remte payment systems Bulk cash smuggling Trade-based mney laundering (e.g., Black Market Pes Exchange [BMPE], freign trade znes [FTZs]) Legal entities (e.g., trusts, shell cmpanies, crpratins, limited liability cmpanies) Natinal Mney Laundering Strategy (NMLS) Written by the U.S. Departments f Hmeland Security, Justice, Treasury, and State, as well as by the Federal Reserve, the OCC, and the FDIC, the NMLS was published in 2007 in direct respnse t the MLTA. Nine key gals were utlined: Cntinuing t safeguard the banking system Enhancing financial transparency in mney services businesses (MSBs) Stemming the flw f illicit bulk cash ut f the United States Attacking trade-based mney laundering at hme and abrad 16

18 Prmting transparency in the wnership f legal entities Examining anti-mney laundering regulatry versight and enfrcement at casins Implementing and enfrcing anti-mney laundering regulatins fr the insurance industry Supprting glbal anti-mney laundering capacity building and enfrcement effrts Imprving hw t measure prgress Internatinal Narctics Cntrl Strategy Reprt (INCSR) An annual reprt issued by the U.S. Department f State that describes the effrts t attack, cuntry by cuntry, all aspects f the internatinal drug trade, as well as chemical cntrl, mney laundering and financial crimes. Cuntry Reprts n Terrrism An annual reprt, previusly knwn as Patterns f Glbal Terrrism, issued by the Department f State that prvides verviews f terrrist activity in cuntries in which acts f terrrism ccurred, cuntries that are state spnsrs f terrrism, and cuntries determined by the U.S. Secretary f State t be f particular interest in the glbal war n terrr. The Cuntry Reprts n Terrrism als cver majr terrrism-related events invlving Americans, infrmatin n terrrist grups, terrrist sanctuaries, terrrist attempts t acquire weapns f mass destructin, statistical infrmatin prvided by the Natinal Cunterterrrism Center (NCTC) n individuals killed, injured r kidnapped by terrrist grups, and bilateral and multilateral cunterterrrism cperatin. Fr additinal guidance issued by key internatinal grups, please refer t the Key Internatinal Grups and Initiatives sectin. Fr details n guidance specific t a particular tpic (e.g., Suspicius Activity Reprts [SARs], crrespndent banking, plitically expsed persns [PEPs], trade finance), please refer t the respective sectins thrughut this publicatin. Financial Crimes Enfrcement Netwrk 23. What is the Financial Crimes Enfrcement Netwrk, and what is its rle in AML regulatin? The Financial Crimes Enfrcement Netwrk (FinCEN), a bureau f the U.S. Treasury Department, was established in 1990 by Treasury Order Its missin is t safeguard the financial system frm abuses f financial crime. It is the Financial Intelligence Unit (FIU) f the United States, frmed t supprt law enfrcement and the financial cmmunity in the fight against mney laundering, terrrist financing and ther financial crimes thrugh the cllectin, analysis and sharing f BSA infrmatin. FinCEN seeks t prvide adequate financial intelligence t law enfrcement withut verburdening the financial cmmunity r cmprmising the privacy f individuals. The many partnerships f FinCEN are nt limited t the United States, but expand internatinally t law enfrcement, financial institutins and regulatry authrities in freign cuntries, as well. While FinCEN relies primarily n federal functinal regulatrs t examine financial institutins and enfrce AML cmpliance, the regulatrs lk t FinCEN fr guidance in the implementatin f the BSA and USA PATRIOT Act. FinCEN has issued regulatins, in cncert with federal functinal regulatrs and the Internal Revenue Service (IRS), related t BSA and AML cmpliance. FinCEN may issue enfrcement actins fr vilatins f the BSA and USA PATRIOT Act thrugh its Office f Enfrcement jintly r unilaterally. The Office f Enfrcement evaluates enfrcement matters, including the assessment f civil mney penalties. 24. In what types f initiatives des FinCEN engage? In 1992, as part f the Annunzi-Wylie Anti-Mney Laundering Act, FinCEN frmed the Bank Secrecy Act Advisry Grup (BSAAG), a task frce established t crdinate and infrm the financial cmmunity abut BSA-related matters. The BSAAG includes senir representatives frm financial institutins, federal law enfrcement agencies, regulatry agencies, and thers frm the public and private sectrs. FinCEN als has created several cmmunicatin systems t facilitate the sharing f infrmatin amng bth dmestic and internatinal entities. The PATRIOT Act Cmmunicatin System (PACS) allws financial institutins t file electrnic BSA frms, such as CTRs and SARs, quickly and securely. The Gateway prgram enables law enfrcement agencies and financial industry regulatrs t have expedited access t BSA recrds filed with FinCEN. The Law Enfrcement and Financial Institutin Infrmatin Sharing (LEFIIS) system allws law enfrcement t receive feedback frm financial institutins n subjects f mney laundering and terrrism investigatins, and is used t facilitate infrmatin sharing amng financial institutins. FinCEN als develped the Egmnt Secure Web (ESW), 17

19 which is a private netwrk that allws cnnected FIUs t interface with FinCEN and each ther t access infrmatin related t mney laundering trends, analytical tls and technlgical develpments via . Additinal tls include the Gegraphic Threat Assessments and Nntraditinal Methdlgies Sectins, a resurce center fr emerging methds f mney laundering and terrrist financing. FinCEN als cllabrates with ther FIUs glbally t exchange infrmatin supprting AML and cunterterrrism initiatives wrldwide, and assists ther cuntries with develping their FIUs. Fr additinal guidance n FIUs, please refer t the Key Internatinal Grups and Initiatives sectin. 25. What resurces has FinCEN prvided t the public? Amng the issuances and resurces prvided by FinCEN are the fllwing: Statutes and Regulatins Resurce that cntains links t BSA and USA PATRIOT Act statutes and cdified regulatins. Federal Register Ntices Links t final regulatins issued after the date f cdificatin as well as Ntices f Prpsed Rulemaking (NPRs) in the Federal Register. Guidance Clarificatin f issues r respnses t questins related t FinCEN regulatins (e.g., cmpletin and filing f Suspicius Activity Reprts [SARs]; applicability f the definitin f a mney services business [MSB] t a particular business activity; applicability f the Safe Harbr prvisin when sharing SARs under certain circumstances). Administrative Rulings Rulings that prvide a new interpretatin f the BSA r any ther statute granting FinCEN authrity, express an pinin abut a new regulatry issue, and/r utline the effect f the varius releases n cvered financial institutins. Advisries/Bulletins/Rulings/Fact Sheets An archive f advisries, advisry withdrawals, bulletins, rulings and fact sheets dating back t Answers t Frequently Asked Bank Secrecy Act (BSA) Questins A list f questins that answer basic questins asked abut BSA and USA PATRIOT laws and regulatins. Reprts and Publicatins Reprts published peridically n key regulatry issues and strategies t address these issues including, but nt limited t, the fllwing: The SAR Activity Review: Trends, Tips & Issues A publicatin prduced apprximately nce r twice each year by FinCEN in cperatin with many regulatry, law enfrcement and industry partners. The publicatin gives the public infrmatin and insight cncerning the preparatin, use and value f SARs filed by institutins. The SAR Activity Review: By the Numbers A publicatin that is generally prduced twice each year as a cmpanin t The SAR Activity Review: Trends, Tips & Issues and prvides numerical data n SAR filings. Financial Institutins Outreach Initiative Reprts sharing infrmatin gathered thrugh varius utreach initiatives with representatives in the financial industry (e.g., large depsitry institutins, MSBs). Strategic Analytical Reprts and Other Publicatins Publicatins addressing ther trends and issues, such as Mrtgage Lan Fraud: An Update f Trends Based upn an Analysis f Suspicius Activity Reprts (April 2008). Annual Reprt Prvides an verview f FinCEN s current state and details the strategies and utcmes f the year s peratins. Reprt t Cngress An archive f reprts made t Cngress by the U.S. Secretary f the Treasury dating back t 2002, including the required annual 361(b) reprt. The Strategic Plan Published peridically, the Strategic Plan details hw FinCEN intends t achieve its current gals in the near future. Bank Secrecy Act/Anti-Mney Laundering Examinatin Manual fr Mney Services Businesses Guidance n the examinatin prcess f MSBs, in English and Spanish. Enfrcement Actins Links t enfrcement actins dating back t

20 Law Enfrcement A summary f supprt services fr law enfrcement and links t law enfrcement case examples that have been assisted by infrmatin reprted under BSA regulatins. News Releases An archive f imprtant FinCEN news releases dating back t Speeches An archive f speeches given by the directr f FinCEN dating back t Testimny An archive f testimny given by the directr f FinCEN dating back t Hw des FinCEN interact with banking and securities regulatrs? In 2004, FinCEN entered int a Memrandum f Understanding (MOU) with federal banking regulatrs. The MOU sets frth prcedures fr the administratin f the BSA, Titles I and II f Pub. L , as amended, cdified at 12 U.S.C. 1829b, 12 U.S.C , and 31 U.S.C ; infrmatin relating t the primary federal regulatrs plicies and prcedures fr examinatin f BSA cmpliance; significant BSA cmpliance issues at banking rganizatins supervised by the regulatrs; and analytical data based n r derived frm infrmatin prvided by the regulatrs. The MOU als gives FinCEN authrity t issue its wn enfrcement actins, even when regulatrs may nt think it is necessary. On April 26, 2005, FinCEN and the New Yrk State Banking Department entered int a similar MOU; shrtly thereafter, a number f ther states fllwed suit. In late 2006, the SEC and FinCEN entered int an MOU under which the SEC prvides FinCEN with detailed infrmatin n a quarterly basis regarding the AML examinatin and enfrcement activities f the SEC and the Self- Regulatry Organizatins (SROs). In return, FinCEN prvides assistance and analytical reprts t the SEC. Enfrcement Actins 27. What types f enfrcement actins are available t regulatrs fr addressing AML Cmpliance Prgram deficiencies and vilatins? Regulatrs have a range f enfrcement tls available t address AML Cmpliance Prgram deficiencies and vilatins f AML laws and regulatins. While enfrcement actins against nnbanks have increased in recent years, the number f enfrcement actins issued by bank regulatrs cntinues t utnumber thse f ther agencies, at least in the United States. Examples f enfrcement actins available t U.S. bank regulatrs in rder f severity are: Cmmitment Letter: A Cmmitment Letter is an agreement between a bank s bard f directrs and a bank regulatr in which the bard, n behalf f a bank, agrees t take certain actins t address issues r cncerns surfaced by the regulatr. A Cmmitment Letter is nt legally binding, but the failure f a bank t live up t the terms f the Cmmitment Letter may subject the bank t mre frmal regulatry actin. Memrandum f Understanding: A Memrandum f Understanding (MOU) is an agreement between a bank s bard f directrs and ne r mre regulatry agencies. The cntent f an MOU may be similar r identical t mre frmal enfrcement actins, but MOUs are nnpublic dcuments and, similar t Cmmitment Letters, nt legally binding. Frmal Agreements: A Frmal Agreement is an agreement between a bank s bard f directrs and ne r mre regulatry agencies. While the cntents f a Frmal Agreement may mirrr thse f an MOU, vilatins f a Frmal Agreement can prvide the legal basis fr assessing civil mney penalties (CMPs) against directrs, fficers and ther institutin-affiliated parties. Cnsent Order r Order t Cease and Desist (C&D): Cnsent Orders and Orders t Cease and Desist are agreements between a bank s bard f directrs and ne r mre regulatry agencies. Vilatins f a Frmal Agreement can prvide the legal basis fr assessing civil mney penalties (CMPs) against directrs, fficers and ther institutin-affiliated parties. The regulatr s decisin t issue a Cnsent Order r Order t Cease and Desist rather than a frmal agreement is based n its assessment f the severity f the bank s prblems. Civil Mney Penalties (CMPs): Civil mney penalties are financial penalties that may be impsed by a regulatr against a bank r an individual(s) fr a vilatin f law r regulatin r nncmpliance with a frmal enfrcement actin. Death Penalty : Under the Annunzi-Wiley Act f 1992, bank regulatrs have the ptin in fact, are bligated t cnsider whether the license/charter f a depsitry institutin that is fund guilty r pleads guilty t mney laundering charges shuld be revked. The revcatin f a license/charter is knwn as the Death Penalty. 19

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