FinCEN released an Alert (FIN-2023-Alert006) to help financial institutions recognize and identify suspicious activity that could be related to the financing of Hamas terrorist activities.
The Alert provides seven red flags to help detect, prevent, and report potential suspicious activity related to Hamas’s terrorist financing activity. It also states, As no single red flag is determinative of illicit or suspicious activity, financial institutions should consider the totality of available facts and circumstances, such as a customer’s historical financial activity, whether the transactions are in line with prevailing business practices, and whether the customer exhibits multiple red flags, before determining that a behavior or transaction is suspicious.
FinCEN asks that any Suspicious Activity Report (SAR) filed for such suspected activity make reference to this Alert by including “FIN-2023-TFHAMAS” in SAR Field 2 (Filing Institution Note to FinCEN) and within the Narrative to indicate a connection between the suspicious activity being reported and the Alert.
Published
2023/10/30