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Certain types of financial transactions serve as indicators, or “red flags” that call for further scrutiny by the financial, commercial, trade and transportation sectors. The indicators listed below may, either by themselves or in conjunction with other factors, raise the level of suspicion regarding a transaction. These indicators are characteristic of the kinds of activity that Cornerstone targets.
Recognizing that these red flags are dynamic and evolving, Cornerstone will continue to appraise the U.S. financial and trade sectors of newly identified indicators through the Cornerstone Report, a quarterly newsletter published by ICE, designed to share information between ICE and the financial and trade community.
Red Flag indicators include:
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Any evidence of structuring, including:
- Frequent transactions or purchase of negotiable instruments $10,000 or under in order to avoid filing a Currency
Transaction Report (CTR).
- Customer making cash deposits $10,000 or under at multiple locations or cash deposits made to one account at
the same location by multiple individuals.
- Customer depositing $10,000 or under after being told of CTR reporting requirement.
- Splitting large currency deposits among several accounts.
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Frequent/unusual use of night deposit drops or ATM machines for deposits.
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Purchase of any monetary instrument by a non-customer with large amounts of currency. |
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Transactions involving a high volume of incoming or outgoing wire transfers, with no logical or apparent purpose,
that comes from, goes to, or transit through locations of concern (i.e., sanctioned countries, sympathizer nations,
non-cooperative nations) Wire transfers by charitable organizations to companies located in countries known to
be bank or tax havens.
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Using multiple accounts to collect funds that are then transferred to the same foreign beneficiaries. |
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Cash debiting schemes in which deposits in the U.S. correlate directly with ATM cash withdrawals in countries of
concern, and vice-versa. |
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Issuing checks, money orders, or other financial instruments, often numbered sequentially, to the same person or
business, or to a person or business whose name is spelled similarly. |
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Reluctance or refusal of individuals to provide identifying information to bank employee. |
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Transactions inconsistent with usual and customary business or personal practices (i.e. wire transfers that do not
coincide with the type of business or activity in which customer is normally engaged; negotiation of third party
checks inconsistent with type of business customer is involved in). |
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Sudden, unexplained change in banking habits or activity. |
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Transfer of funds to a commercial account with no logical relationship or connection to the sender of the funds (i.e.
jewelry store account wiring money to auto parts exporter).
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TO REPORT SUSPICIOUS ACTIVITY, PLEASE CONTACT:
1-866-DHS-2-ICE
NOTE: Voluntarily reporting suspicious activity to ICE does not replace the legal obligation to file Suspicious Activity Reports, or other reports mandated by the Bank Secrecy Act, USA PATRIOT Act, or any other government regulation. For more information, visit the FinCEN and the Treasury Department websites.
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