Information on Narcotics and Bulk Currency Corridors (FinCEN Advisory – FIN-2011-A009)

Department of the Treasury
Financial Crimes Enforcement Network
Advisory
FIN-2011-A009
Issued: April 21, 2011
Subject: Information on Narcotics and Bulk Currency Corridors The Financial Crimes Enforcement Network (FinCEN) is issuing this Advisory to draw the attention of financial institutions to narcotics and bulk currency corridors in the United States. The goal is to assist financial institutions in developing a better understanding of their own geographic locations, how these locations intersect with established flows of narcotics and bulk currency, and how geographic location may affect Bank Secrecy Act (BSA) obligations. Identifying Narcotics and Bulk Currency Corridors The trafficking of illegal drugs, fueled in part by a continuing demand for illegal narcotics in the United States, has created an established pattern of narcotics distribution channels and disposition of illicit funds. The Office of National Drug Control Policy has identified High Intensity Drug Trafficking Areas (HIDTA), indicating areas of specific concern.1 Additionally, financial institutions may find the U.S. Department of Justice’s National Drug Threat Assessment useful, specifically to identify areas that may be hubs of activity as well as logistical highways in the drug trade.2 These resources may help financial institutions determine if they are located either in a HIDTA or in a region that is located in the supply chain for narcotics and bulk currency smuggling. Financial institutions may wish to pay particular attention to Appendix A of the 2010 National Drug Threat Assessment, the National Drug Intelligence Center Dynamic Mapping Initiative, 3 and the Department of Justice’s Regional Drug Transportation Corridors.4 These visual representations may assist financial institutions in identifying geographic regions that, although not in HIDTA locations, are located in the logistical channels of transportation of narcotics and bulk currency. The narcotics and currency corridors have resulted in corresponding illicit financial activity, the likely goal of which is to limit the time and expense related to physically transporting illicit bulk currency. This activity may be a version of what is referred to as inter-state cash, pass-through activity, or funnel account activity. Funnel account activity often involves a customer structuring currency deposits into an account in one geographic area, with the funds subsequently withdrawn in a different geographic region with little turn-around time. The rapid flow of funds may also span a large geographic area between the deposits and withdrawals, including instances where the deposit location is 1 http://www.whitehousedrugpolicy.gov/publications/pdf/HIDTA_fs.pdf 2 http://www.justice.gov/dea/concern/18862/ndic_2010.pdf 3 http://www.ndicgis.usdoj.gov//Maps.aspx 4 http://www.justice.gov/ndic/pubs38/38661/images/figure3.jpg