AL 2002-10
Advisory Letter

Subject: U.S. Department of Treasury FinCEN Advisories 20A, 22A,
         and 25A

Date:    December 9, 2002

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

This advisory letter revises the list of countries detailed in OCC 
Advisory Letter (AL) 2002-7, “U.S. Department of Treasury FinCEN 
advisories 17A, 18A, and 26A,” dated October 10, 2002 (see also 
AL 2002-5, AL 2002-2, AL 2001-7, and AL 2000-8). 

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.  Since then, FinCEN has issued additional 
advisories eliminating or revising some of those original 
advisories. 

The attached FinCEN advisories 20A, 22A, and 25A supersede and 
withdraw FinCEN advisories 20, 22, and 25, issued July 2000, 
regarding the jurisdictions of the Marshall Islands, Niue, and the 
Russian Federation. Enhanced scrutiny of transactions with these 
jurisdictions is no longer necessary due to the enactment of 
significant reforms to their counter-money-laundering systems and 
the concrete steps taken to bring these reforms into effect. The 
FinCEN advisories are consistent with the October 11 Financial 
Action Task Force on Money Laundering decision to remove the 
Marshall Islands, Niue, and the Russian Federation from its list of 
countries that are noncooperative in the fight against money 
laundering.

FinCEN advisories remain in effect for the following jurisdictions:

The Arab Republic of Egypt,
Burma,
The Cook Islands,
Dominica,
The Federal Republic of Nigeria,
Grenada,
Nauru,
The Philippines,
St. Vincent and The Grenadines, 
The Seychelles, and
Ukraine.

The FinCEN advisories on the above jurisdictions 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 advisory letter, 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 
[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 Compliance 
Division at (202) 874-4428.




__________________
David G. Hammaker
Deputy Comptroller for Compliance



Attachments

Can found electronically at:
[ http://www.fincen.gov/pub_main.html ]