Regulatory Alerts2012-10-22 | FinCEN Advisory – FIN-2012-A010Added
Risk Associated with Third-Party Payment Processors (FinCEN Advisory – FIN-2012-A010)
This advisory provides guidance to financial institutions on filing Suspicious Activity Reports (SARs) for activities involving third-party payment processors. It identifies specific red flags for illicit use, including high rates of consumer complaints, accounts at multiple financial institutions, money laundering attempts, and solicitation by distressed banks. Financial institutions are advised to update anti-money laundering programs and conduct thorough due diligence regarding pending legal actions and necessary licenses. When reporting suspicious activity, institutions must check the appropriate box on the SAR form and include the term "Payment Processor" in both the narrative and subject occupation portions.