All in BSA

On March 2, 2023, the OFAC sanctioned eight Mexican companies linked to timeshare fraud on behalf of the Cartel de Jalisco Nueva Generacion (CJNG). A timeshare is a shared ownership model of vacation real estate in which multiple purchasers own allotments of usage in the same property. Timeshare fraud happens when scam artists call sellers of timeshares, posing as a reseller or real estate agent, then claims to have a buyer for the timeshare or guarantees he can sell the timeshare for a good price.

On January 25, 2023, FinCEN issued an alert to financial institutions on potential investments in the U.S. commercial real estate sector by sanctioned Russian elites, oligarchs, their family members, and the entities through which they act. The alert lists potential red flags and typologies involving attempted sanctions evasion in the commercial real estate sector, and reminds financial institutions of their Bank Secrecy Act (BSA) reporting obligations. 

VIDEO: Reporting a SAR on a Director to the Board

In this Compliance Clip (video), Adam discusses options for reporting a SAR to the board of directors when the SAR is on a director. He also discusses what to do if the SAR is on a member of senior management, like the president of the financial institution. This is a must-watch video for any BSA professional.

On January 18, 2023, FinCEN issued an order that identifies the virtual currency exchange Bitzlato Limited (Bitzlato) as a “primary money laundering concern” in connection with Russian illicit finance. This is the first order issued pursuant to section 9714(a) of the Combating Russian Money Laundering Act, as amended, and highlights the serious threat that business operations that facilitate and support Russian illicit finance pose to U.S. national security and the integrity of the U.S. financial sector. 

On January 13, 2023, FinCEN issued an alert which aims to better aid financial institutions in the detection of financial activity related to human smuggling along the southwest border of the United States. The alert provides trends and typologies specifically related to human smuggling occurring along the SW border. It also provides red flag indicators to help financial institutions better identify transactions potentially related to human smuggling and reminds financial institutions of their Bank Secrecy Act (BSA) reporting obligations.

On November 30, 2022, the FATF released its first ever report on money laundering from fentanyl and synthetic opioids with recommendations for countering financial flows from the illicit drug trade, which claims thousands of lives around the world. The report, which was co-led by the United States and Canada, looks at the way proceeds are laundered from synthetic opioids trafficking.