Regulatory Alerts1996-10-01 | FinCEN Advisory - Issue 6Added
Mexican Bank Drafts and Factored Third Party Checks
Banks and other financial institutions are directed to apply enhanced scrutiny to deposits or collections of U.S. dollar-denominated bank drafts drawn by Mexican banks and to bundled third-party checks endorsed to currency exchange houses or other businesses. Institutions subject to the Bank Secrecy Act must examine facts surrounding transactions involving persons with no apparent business basis for presenting such instruments, particularly those lacking a fixed address or substantial commerce with Mexico, and monitor for periodic surges in volume or accounts concentrating cash prior to wiring funds abroad. Suspicious activity reporting rules under 31 CFR 103.21 apply to these transactions, and the Treasury Department confirms that reports regarding such activities are protected from disclosure and liability under 31 U.S.C. 5318(g)(2) and (g)(3).