AL 2001-7
Advisory Letter
Subject: U.S. Department of Treasury FinCEN Advisories 
         13A, 14A, 19A, 23A
Date:    July 25, 2001

To: Chief Executive Officers and Compliance Officers
    of National Banks and Federal Branches, Department 
    and Division Heads, and Examining Personnel

This advisory letter revises the list of countries 
detailed in OCC Advisory Letter (AL) 2000-8, "U.S. 
Department of Treasury FinCEN Advisories 13 through 27,"
dated August 9, 2000.

In July 2000, the U.S. Department of the Treasury's 
Financial Crimes Enforcement Network (FinCEN) issued a 
series of advisories identifying 15 countries with 
serious deficiencies in their counter-money-laundering 
systems.  See FinCEN Advisories 13 - 27 (July, 2000).  
The FinCEN advisories are available at 
< www.treas.gov/fincen > and additional guidance is 
provided in OCC AL 2000-8.  Due to the enactment of 
significant reforms to their counter-money-laundering 
systems and the concrete steps being taken to bring these
reforms into effect, FinCEN recently withdrew four of the
advisories pertaining to the following jurisdictions:

· The Bahamas,
· The Cayman Islands,
· Liechtenstein, and
· Panama.

FinCEN advisories 13A, 14A, 19A and 23A, issued in June 
2001, supercede FinCEN Advisories 13, 14, 19, and 23, 
issued in July 2000.  

FinCEN's withdrawal of its previous advisories is 
consistent with the recent decision of the Financial 
Action Task Force on Money Laundering (FATF) to remove 
the subject countries from its list of countries that are
considered non-cooperative in the fight against money 
laundering.   In its June 2001 report (available at 
< http://www.oecd.org/fatf/pdf/PR-20010622_en.pdf >, the 
FATF has also identified six additional countries that 
are problematic in this regard:  Egypt, Guatemala, 
Hungary, Indonesia, Myanmar, and Nigeria.  FinCEN is 
currently evaluating the FATF analysis of these countries 
and will issue additional guidance, as appropriate. As 
reflected in this recent FATF decision, these 
jurisdictions have in place counter-money-laundering 
systems that generally meet international standards.  

The withdrawal of these FinCEN advisories does not 
relieve institutions of their pre-existing and on-going 
obligation to report suspicious activity, as set forth in 
31 CFR 103.18, as well as their obligation to comply with 
all other applicable provisions of law.  Moreover, FinCEN 
advisories remain in effect for the following 
jurisdictions [See FinCEN advisories 15-18, 20-22 & 24-27
(July 2000)]:

· The Cook Islands,
· Dominica,
· Israel,
· Lebanon,
· The Marshall Islands,
· Nauru,
· Niue,
· The Philippines,
· The Russian Federation,
· St. Kitts and Nevis, and
· St. Vincent and The Grenadines.

The FinCEN advisories emphasize the need for enhanced 
scrutiny of certain transactions and banking 
relationships in these jurisdictions to ensure that 
appropriate measures are taken to minimize risk for money 
laundering.  Please refer to OCC AL 2000-8 for additional
information on banking relationships in the subject 
jurisdictions.  Also refer to the Bank Secrecy Act/Anti-
money Laundering booklet in the Comptroller's Handbook 
and OCC AL 2000-3 for guidance on controlling risk of 
money laundering.  Copies of the booklet and the OCC 
advisory letters are available at 
< www.occ.treas.gov/handbook/bsa.pdf > and 
< http://www.occ.treas.gov/Advlst00.htm >.

If you have any questions, or need copies of the new 
FinCEN advisories, please contact your supervisory office 
or the Community and Consumer Policy Division at 
(202) 874-4428.



__________________

Ralph E. Sharpe
Deputy Comptroller
Community and Consumer Policy