Regulatory Alerts2013-09-27 | FinCEN Advisory - FIN-2013-A007Added
Supplement on U.S. Currency Restrictions on Banks in Mexico (FinCEN Advisory - FIN-2013-A007)
FinCEN updates U.S. financial institutions on regulatory restrictions imposed on Mexican financial institutions for transactions in U.S. currency, noting a 63 percent reduction in the quarterly average exportation of U.S. cash from Mexican banks between 2009 and 2012. The advisory highlights that illicit actors may utilize different methodologies, such as using financial institutions with higher dollar thresholds or moving funds through other jurisdictions, to repatriate illicit proceeds. U.S. financial institutions are advised to consider previous advisories and CNBV guidance, maintain policies to mitigate risks associated with bulk cash shipments and correspondent banking, and continue including the term “MX Restriction” in the narrative portion of Suspicious Activity Reports to indicate a possible connection to the enacted restrictions.