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6/11/2010 11:26:46 AM
MSB List Updated as of May 18, 2010

Source: FinCEN


 


This new May 2010 List, which is current as of May 18, 2010, contains data on 42,699 registered MSBs. This is an increase of 497 MSB registrations from the April, 2010 total of 42,202. See attached document.

6/11/2010 11:32:33 AM
Law Enforcement Information Sharing June 2010

 


Law Enforcement Information Sharing with the Financial Industry report and numbers availabel as of June 1, 2010. Reprot contains the date, case number, and number of persons of interest.


Link: http://fincen.gov/statutes_regs/patriot/pdf/leinfosharing.pdf

6/11/2010 11:35:37 AM
314a Fact Sheet-June 1, 2010

Source: FinCEN


314a Fact Sheet released June 1, 2010. 


http://fincen.gov/statutes_regs/patriot/pdf/314afactsheet.pdf


To date, the 314(a) process already has proved to be successful, as illustrated below. Results have yielded productive leads for both terrorist financing and money laundering investigations. The immediate matches have, for example, led to the identification of new accounts, transactions, indictments, etc. and enabled law enforcement to efficiently direct its use of legal processes to promptly obtain critical evidence in numerous cases. Examples of 314(a) requests, based on money laundering, include:


• Hawala operation involving a sanctioned country


• Arms trafficking


• Alien smuggling resulting in fatalities


 


• Cigarette smuggling


• Nationwide investment fraud with many victims


• International criminal network involved in identity theft and wire fraud


• Multi-agency investigation of drug trafficking rings


Results


To date, the 314(a) Program Office has processed 1190 requests pertinent to the following significant criminal investigations:


Terrorism/Terrorist Financing – 340 cases


Money Laundering – 850 cases


These requests included 11,577 subjects of interest. Of these, financial institutions have responded with 77,291 total subject matches: 76,253 positive and 1,038 inconclusive.


Feedback from Law Enforcement


Based upon the fifty-one percent of 314(a) feedback that has been received from the law enforcement requesters, the following information has been provided. The aggregate numbers yielded from all of the feedback responses factored by the number of related requests, reveal that, on the average, there were:


8.5 New Accounts Identified per request


14.4 New Transactions Identified per request


7.6 Follow up initiatives taken by Law Enforcement with Financial Institutions per request

6/11/2010 11:38:15 AM
314(a) direct match

Karie,


We would like to answer for you and provide best practices; therefore, moved to the section under Ask the AMLA Expert.


Mary Meile 

6/15/2010 3:13:38 PM
EU and US draft agreement on bank data transfers

Please see the attached document. This is good news for the banks as we will be able to trace international transactions that might be related to terrorist activity funds.  

6/16/2010 11:53:09 AM
US Gang Data by State and Ranges by County

Source: National Drug Threat Assessment Report 2010


Gang Membership by County Click on the link to view the US MAP


http://www.justice.gov/ndic/pubs38/38661/images/mapA4.jpg


U.S. map showing gang membership ranges by county.


The states that have counties with 10,001 or more gang members are California, Arizona, and Illinois.


The states that have counties with 3,501 to 10,000 gang members are Washington, California, Nevada, Arizona, Utah, New Mexico, Texas, Oklahoma, Missouri, Florida, Tennessee, Illinois, Michigan, Ohio, New Jersey, and New York.


The states that have counties with 2,501 to 3,500 gang members are California, Nevada, Nebraska, Kansas, Texas, Minnesota, Missouri, Arkansas, Alabama, Georgia, Florida, South Carolina, North Carolina, Wisconsin, Illinois, Michigan, Indiana, New Jersey, New York, and Massachusetts.


The states that have counties with 501 to 2,500 gang members are Washington, Oregon, California, Nevada, Arizona, Utah, Colorado, New Mexico, Texas, Oklahoma, Kansas, Nebraska, Minnesota, Iowa, Arkansas, Louisiana, Mississippi, Alabama, Georgia, Florida, South Carolina, North Carolina, Tennessee, Virginia, Wisconsin, Illinois, Indiana, Ohio, Michigan, Maryland, Pennsylvania, New Jersey, New York, Connecticut, Massachusetts, and Hawaii.


All states have at least one county with 1 to 500 gang members.


All states have at least one county with 0 gang members except for Arizona, Connecticut, Rhode Island, and Massachusetts.


All states and Puerto Rico have at least one county that did not report gang members except for New Hampshire, Rhode Island, Maryland, Delaware, and New Jersey.

6/16/2010 12:12:40 PM
Map of Greatest Drug Threat-Region-State and Local

Source: National Drug Threat Assessment Report 2010  Click on the link for the Map and Stats.


http://www.justice.gov/ndic/pubs38/38661/images/mapA5.jpg


U.S. map with charts showing the greatest drug threat, by region, for 2009, as reported by state and local agencies.


In the Pacific region, 5.5% of state and local agencies reported cocaine as the greatest drug threat; 1.3% reported heroin as the greatest drug threat; 79.5% reported methamphetamine as the greatest drug threat; 5.7% reported marijuana as the greatest drug threat; and 7.2% reported controlled prescription drugs as the greatest drug threat.


In the West Central region, 19.3% of state and local agencies reported cocaine as the greatest drug threat, 4.8% reported heroin as the greatest drug threat; 60.3% reported methamphetamine as the greatest drug threat; 7.9% reported marijuana as the greatest drug threat; and 7.3% reported controlled prescription drugs as the greatest drug threat.


In the Southwest region, 23.8% of state and local agencies reported cocaine as the greatest drug threat, 2.6% reported heroin as the greatest drug threat; 57.0% reported methamphetamine as the greatest drug threat; 12.0% reported marijuana as the greatest drug threat; and 3.2% reported controlled prescription drugs as the greatest drug threat.


In the Southeast region, 60.2% of state and local agencies reported cocaine as the greatest drug threat, 1.1% reported heroin as the greatest drug threat; 22.8% reported methamphetamine as the greatest drug threat; 5.3% reported marijuana as the greatest drug threat; and 9.6% reported controlled prescription drugs as the greatest drug threat.


In the Great Lakes region, 38.8% of state and local agencies reported cocaine as the greatest drug threat, 16.8% reported heroin as the greatest drug threat; 15.0% reported methamphetamine as the greatest drug threat; 15.7% reported marijuana as the greatest drug threat; and 12.7% reported controlled prescription drugs as the greatest drug threat.


In the Mid-Atlantic region, 40.0% of state and local agencies reported cocaine as the greatest drug threat, 30.9% reported heroin as the greatest drug threat; 2.0% reported methamphetamine as the greatest drug threat; 14.5% reported marijuana as the greatest drug threat; and 12.3% reported controlled prescription drugs as the greatest drug threat.


In the Florida/Caribbean region, 62.1% of state and local agencies reported cocaine as the greatest drug threat, 0.4% reported heroin as the greatest drug threat; 10.2% reported methamphetamine as the greatest drug threat; 9.4% reported marijuana as the greatest drug threat; and 17.9% reported controlled prescription drugs as the greatest drug threat.


In the New York/New Jersey region, 40.6% of state and local agencies reported cocaine as the greatest drug threat, 27.8% reported heroin as the greatest drug threat; 0.0% reported methamphetamine as the greatest drug threat; 23.0% reported marijuana as the greatest drug threat; and 8.0% reported controlled prescription drugs as the greatest drug threat.


In the New England region, 29.6% of state and local agencies reported cocaine as the greatest drug threat, 39.2% reported heroin as the greatest drug threat; 0.8% reported methamphetamine as the greatest drug threat; 16.2% reported marijuana as the greatest drug threat; and 13.9% reported controlled prescription drugs as the greatest drug threat.


Source: National Drug Intelligence Center's National Drug Threat Survey 2009.

6/16/2010 12:21:07 PM
Gangs with Significant Influence-U.S. Drug Market

Source: United States Department of Justice, Attorney General's Report to Congress on Growth of Violent Street Gangs, in Suburban Areas, April 2000; High Intensity Drug Trafficking Area reporting.


See Attached.

6/17/2010 11:40:27 AM
US Sanctions Against Iran's Nuclear Program

Comments by Mary Meile: Please take the time to read the following points listed below as this is critical to understanding the strategy that the US is implementing in response to the UN Security Council meeting held last week regarding Iran's nuclear program.  If you are training on OFAC sanctions at your institution then you need to understand what has been added and WHY.  



First, we are designating Iran's Post Bank for its support of proliferation activities. This brings the number of Iranian-owned banks on our list to 16.


Second, we are adding five front companies and more than ninety ship names that Iran's national maritime carrier has been using to try and evade sanctions.


Third, we are adding two individuals and four entities that are part of Iran's Revolutionary Guard, which plays a key role in Iran's missile programs and support for terrorism.


Fourth, we are adding two individuals and two entities that are actively involved in Iran's nuclear or missile programs.


And finally, we are identifying 22 petroleum, energy and insurance companies – located inside and outside Iran – that are owned or controlled by the Iranian government.

6/17/2010 11:43:44 AM
Under Secretary Levy-IRAN Nuclear Program

Under Secretary Levey for Terrorism and Financial Intelligence
Stuart Levey
Remarks on Designations Targeting Iran’s Nuclear
and Missile Programs
June 16, 2010
As Prepared for Delivery


As Secretary Geithner said, we are taking a series of steps today to impose additional consequences on Iran for its continuing failure to meet its international obligations.     


First, we are sanctioning an additional Iranian bank, Post Bank.  At one time, Post Bank's business was conducted almost entirely within Iran.  But when some of Iran's largest banks were exposed for financing proliferation, Iran began to use Post Bank to facilitate international trade.  In fact, Post Bank stepped into the shoes of Bank Sepah, which is under UN sanctions, to carry out Bank Sepah's transactions and hide its identity.  International banks that would never deal with Bank Sepah have been handling these transactions that they think are really for Post Bank.


Second, we are taking action against Iran's national maritime carrier, IRISL.  Since we sanctioned IRISL in 2008, it has desperately attempted to evade those sanctions, setting up new front companies, renaming and even repainting vessels to hide their true ownership.  Despite its deceptive maneuvers, IRISL has had to struggle to obtain insurance and other services.  


Third, we are taking further action against the IRGC, or Islamic Revolutionary Guards Corps.  The IRGC plays a key role in Iran's missile program and support for terrorism and it has taken over broad portions of the Iranian economy, to the detriment of the Iranian people.  With today's designations, we have now sanctioned 26 entities and individuals connected to the IRGC, and we will continue to do so. No IRGC entity should have any place in the world's legitimate financial system.


Fourth, we are sanctioning two individuals and two entities for proliferation, including a key broker used by Iran to procure a variety of nuclear-related equipment. 


Finally, we are identifying 22 petroleum, energy, and insurance companies owned or controlled by the Government of Iran, including 17 located outside Iran and many that are not easily identifiable as Iranian.  Americans have long been forbidden to do business with Iranian entities.  Companies around the world are increasingly deciding not to do business with the government of Iran because of its illicit conduct and because, as President Obama said last week, it is a government "that brutally suppressed dissent and murdered the innocent."  The UN has also highlighted proliferation concerns surrounding Iran's energy sector, and all companies must be conscious of the implications of any trade they conduct with Iran's energy companies.


We know that officials in Iran have been anxious about this new round of sanctions.  If the Iranian Government holds true to form, it will scramble to identify "work-arounds" – hiding behind front companies, doctoring wire transfers, falsifying shipping documents.   We will continue to expose this deception thereby reinforcing the very reasons why the private sector is increasingly shunning Iran.


We will also work to ensure international sanctions are enforced.  In this regard, the State Department has dedicated a senior official, Bob Einhorn, to ensure that we accomplish this in cooperation with our friends and partners around the world.  We are fortunate to have someone of Bob's stature and experience working on this issue.


The overall result of these efforts is that Iran's choice will become increasingly clear – to choose the path offered by President Obama and the international community or to remain on a course that leads to further isolation.

6/17/2010 11:45:24 AM
Link to Iran Sanctions as of June 17, 2010

 


 


http://www.treas.gov/offices/enforcement/ofac/programs/iran/iran.shtml

6/17/2010 11:49:16 AM
IRAN Fact Sheet June 16, 2010

See attached document which exlplains in detail the recent changes.

6/23/2010 6:22:54 AM
Anti-Narcotics Designations Removals/Balkans

The following deletions have been made to OFAC's SDN list:

CARRILLO SILVA, Armando, c/o DROGAS LA REBAJA, Cali, Colombia; c/o INVERSIONES CAMINO REAL S.A., Cali, Colombia; c/o GRACADAL S.A., Cali, Colombia; c/o INTERAMERICA DE CONSTRUCCIONES S.A., Cali, Colombia; c/o ASESORIAS DE INGENIERIA EMPRESA UNIPERSONAL, Cali, Colombia; c/o DISTRIBUIDORA SANAR DE COLOMBIA S.A., Cali, Colombia; c/o PROSPECTIVA EMPRESA UNIPERSONAL, Cali, Colombia; c/o TECNICAS CONTABLES Y ADMINISTRATIVAS, Cali, Colombia; c/o DISTRIBUIDORA DEL VALLE E.U., Cali, Colombia; c/o PROVIDA E.U., Cali, Colombia; DOB 11 Feb 1949; Cedula No. 16242828 (Colombia); Passport 16242828 (Colombia) (individual) [SDNT]

HALILOVIC, Sefer; DOB 6 Jan 1952; POB Prijepolje, Serbia and Montenegro; ICTY indictee (individual) [BALKANS]

MONDRAGON DE RODRIGUEZ, Mariela, c/o MARIELA DE RODRIGUEZ Y CIA. S. EN C., Cali, Colombia; c/o INVERSIONES Y CONSTRUCCIONES COSMOVALLE LTDA., Cali, Colombia; c/o COMPAX LTDA., Cali, Colombia; c/o LABORATORIOS KRESSFOR DE COLOMBIA S.A., Bogota, Colombia; c/o CORPORACION DEPORTIVA AMERICA, Cali, Colombia; c/o INVERSIONES MONDRAGON Y CIA. S.C.S., Cali, Colombia; c/o MARIELA MONDRAGON DE R. Y CIA. S. EN C., Cali, Colombia; c/o CREDIREBAJA S.A., Cali, Colombia; c/o INVERSIONES Y DISTRIBUCIONES A M M LTDA., Cali, Colombia; DOB 12 Apr 1935; Cedula No. 29072613 (Colombia); Passport 4436059 (Colombia) (individual) [SDNT]

RODRIGUEZ ABADIA, William, c/o ALERO S.A., Cali, Colombia; c/o DISTRIBUIDORA MIGIL LTDA., Cali, Colombia; c/o DERECHO INTEGRAL Y CIA. LTDA., Cali, Colombia; c/o M. RODRIGUEZ O. Y CIA. S. EN C., Cali, Colombia; c/o INVERSIONES MIGUEL RODRIGUEZ E HIJO, Cali, Colombia; c/o DISTRIBUIDORA DE DROGAS CONDOR LTDA., Bogota, Colombia; c/o INVERSIONES ARA LTDA., Cali, Colombia; c/o INTERAMERICA DE CONSTRUCCIONES S.A., Cali, Colombia; c/o DEPOSITO POPULAR DE DROGAS S.A., Cali, Colombia; c/o ANDINA DE CONSTRUCCIONES S.A., Cali, Colombia; c/o DISTRIBUIDORA DE DROGAS LA REBAJA S.A., Bogota, Colombia; c/o BLANCO PHARMA S.A., Bogota, Colombia; c/o LABORATORIOS BLAIMAR DE COLOMBIA S.A., Bogota, Colombia; c/o RADIO UNIDAS FM S.A., Cali, Colombia; c/o ASPOIR DEL PACIFICO Y CIA. LTDA., Cali, Colombia; c/o RIONAP COMERCIO Y REPRESENTACIONES S.A., Quito, Ecuador; c/o VALORES MOBILIARIOS DE OCCIDENTE S.A., Bogota, Colombia; c/o LABORATORIOS KRESSFOR DE COLOMBIA S.A., Bogota, Colombia; c/o REVISTA DEL AMERICA LTDA., Cali, Colombia; c/o MUNOZ Y RODRIGUEZ Y CIA. LTDA., Cali, Colombia; c/o CLAUDIA PILAR RODRIGUEZ Y CIA. S.C.S., Bogota, Colombia; c/o PRODUCCIONES CARNAVAL DEL NORTE Y COMPANIA LIMITADA, Cali, Colombia; c/o CREDIREBAJA S.A., Cali, Colombia; c/o ASISTENCIA PROFESIONAL ESPECIALIZADA EN COLOMBIA LIMITADA, Cali, Colombia; c/o BONOMERCAD S.A., Bogota, Colombia; c/o DECAFARMA S.A., Bogota, Colombia; c/o DROCARD S.A., Bogota, Colombia; c/o SEGUWRA DEL VALLE E.U., Cali, Colombia; DOB 31 Jul 1965; Cedula No. 16716259 (Colombia) (individual) [SDNT]

RODRIGUEZ RAMIREZ, Andre Gilberto, Calle 10 No. 4-47 piso 18, Cali, Colombia; c/o ANDINA DE CONSTRUCCIONES S.A., Cali, Colombia; c/o BONOMERCAD S.A., Bogota, Colombia; c/o CAFE ANDINO S.L., Madrid, Spain; c/o CONSULTORIA SANTAFE E.U., Bogota, Colombia; c/o CREDIREBAJA S.A., Cali, Colombia; c/o DECAFARMA S.A., Bogota, Colombia; c/o DISTRIBUIDORA SANAR DE COLOMBIA S.A., Cali, Colombia; c/o DROCARD S.A., Bogota, Colombia; c/o FOGENSA S.A., Bogota, Colombia; c/o INVERSIONES RODRIGUEZ RAMIREZ Y CIA. S.C.S., Cali, Colombia; c/o INVERSIONES Y CONSTRUCCIONES ABC S.A., Cali, Colombia; c/o ALERO S.A., Cali, Colombia; DOB 22 Mar 1972; Cedula No. 16798937 (Colombia); Passport 16798937 (Colombia) (individual) [SDNT]

6/23/2010 6:40:07 AM
Checklists For RDC

Our MidWest Chapter leader, Michelle Hemerley, has provided us with three checklists to assist with the remote deposit capture product which also include the ACH and third party payment processors. You should find these to be very useful. See the attached.


The three checklists are:


  1. New Account BSA/Credit Document Checklist- Remote Deposit Capture Account


  2. BSA/Credit Document Review Checklist for Third Party Service Provider ACH/RCC Account


  3. RDC/ACH/Third Party Site Inspection Checklist


Thank you for sharing Michelle!


6/23/2010 2:25:21 PM
FFIEC BSA/AML Manual Links and Copies

I have the links for the manual in PDF and the infobase to search on the FFIEC site; however, it appears it will not be out for print until July. See below.


FFIEC Bank Secrecy Act/Anti-Money Laundering Examination Manual (April 2010) Spiral-bound print version for sale starting July 2010. Purchasing details to come.) This is from the OCC website.


http://www.occ.treas.gov/pubs1.htm


http://www.fincen.gov/news_room/nr/pdf/20100429.pdf     Fincen Notice


 http://www.ffiec.gov/bsa_aml_infobase/default.htm.  (2010 manual itself)


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