When it comes to identifying potentially suspicious and/or illegal activity such as drug trafficking, one of the best things you can do is to simply create awareness. Train your people, teach them what to look for, tailor training to their specific duties, etc. An excellent resource to help you are red flags identified by the regulatory agencies. Here are just a few of the many red flags related to fentanyl trafficking outlined in a FinCEN Advisory (FIN-2019-A006) :
- Account owners or third parties structure cash deposits at bank branches nationwide into the same account, which funds outgoing transactions on the SWB, including cash withdrawals or wire transfers to Mexico (i.e., funnel account activity and rapid movement of funds).
- The depository institutions have a suspicion concerning the physical condition of deposited banknotes (e.g., the bills smell of drugs, detergent, or are excessively worn).
- The source of funds cannot be corroborated.
- Multiple transactions below the applicable Currency Transaction Report (CTR) threshold (i.e., structuring), which may involve additional indicators:
- Suspicious use of multiple locations.
- Two or more individuals working together.
- Suspicious use of multiple accounts.
- Transaction out of pattern for customers or business type.
- Transaction with no apparent business purpose.
Kevin explains more in the video.
Published
2023/08/08