Combating Money Laundering and Terrorist Financing:
BSA High Risk Designations, OCC Alerts, FinCEN Advisories, and OFAC Lists

• OCC Alerts - notify national banks about fraudulent banking activities. You may provide comments to us or request additional information on any OCC Alert or fraud related OCC issuance through the OCC Alert Responses e-mail contact point.

• OCC BankNet - The OCC's secure BankNet web-site provides access to authorized national bank users to various information on potential terrorist activity that the FBI or other law enforcement agencies may issue. Access and use of BankNet can be found at: http://www.occ.treas.gov/ftp/alert/2002-11.pdf

• FinCEN Advisories -http://www.fincen.gov/pub_main.html - are guidance documents issued to financial institutions.

• Financial Action Task Force (FATF) NCCTs - The FATF is engaged in a major initiative to identify non-cooperative countries and territories (NCCTs) in the fight against money laundering. FATF's current list of non-cooperative countries and territories can be found at: http://www.fatf-gafi.org/pages/0,2987,en_32250379_32235720_1_1_1_1_1,00.html

• High Risk Money Laundering and Related Financial Crimes Areas (HIFCAs) - are a means of concentrating law enforcement efforts at the federal, state, and local levels in high intensity money laundering zones.  HIFCAs may be defined geographically or they can also be created to address money laundering in an industry sector, a financial institution, or group of financial institutions. A list of designated HIFCAs can be found at: http://www.whitehousedrugpolicy.gov/index.html

• High-Intensity Drug Trafficking Areas (HIDTAs) - HIDTAs are designated by the Director of the Office of National Drug Control Policy, in consultation with the Attorney General, Secretary of Treasury, heads of drug-control agencies, and respective governors. HIDTA regions are comprised of specific designated counties, based on the drug threat facing that area. A list of designated HIDTAs can be found at: http://www.whitehousedrugpolicy.gov/hidta/index.html

• International Narcotics Control Strategy Report (INCSR), published annually by the U.S. State Department identifies major money laundering countries and jurisdictions: http://www.state.gov/g/inl/rls/nrcrpt/2003/vol2/html/index.htm

• Institutions of Primary Money Laundering Concerns - Section 5318A of the Bank Secrecy Act, as added by section 311 of the USA PATRIOT Act, authorizes the Secretary of the Treasury to designate a foreign jurisdiction, institution, class of transaction, or type of account as being of "primary money-laundering concern," and to impose one or more of five "special measures." A listing of current or proposed designations can be found at BSA Guidance for Bankers and Examiners.

• Office of Foreign Asset Control (OFAC) Sanctioned Countries & SDNs - OFAC is responsible for issuing regulations that restrict transactions by U.S. persons or entities (including banks) with certain foreign countries, their nationals, or "specially designated nationals (SDNs)." Violations of these laws can expose financial institutions to substantial penalties. A current list of sanctioned countries and SDNs is available at: http://www.treas.gov/offices/enforcement/lists//

• Section 314(a) Information Requests - FinCEN regularly (generally bi-weekly) requests financial institutions search records for persons that may be involved in terrorism or money laundering. Requests are sent to points of contact (POCs) at financial institutions. If your institution needs to change its POC, please file an amended Call Report with the updated information. See OCC Alert 2004-6 for additional information. If your bank is having problems receiving the 314(a) list from FinCEN, please ensure that your POC information is correct on the Call Report and file an amended Call Report, if necessary. Also, ensure that e-mails from FinCEN are not being blocked or restricted by your institution's software or firewalls. More information on the 314(a) requests can be found at: http://www.fincen.gov.

• U. S. Money Laundering Threat Assessment (MLTA) - The MLTA is the first government-wide analysis of money laundering. This report investigates money laundering vulnerabilities across a spectrum of techniques used by criminals. It offers a detailed analysis of thirteen money laundering methods, ranging from well-established techniques for integrating "dirty money" into the financial system to modern innovations and emerging industries.