Regulatory Alerts2000-07-01 | FinCEN Advisory - Issue 23Added
Transactions Involving Panama (FinCEN Advisory - Issue 23)
Banks and other financial institutions operating in the United States are advised to carefully consider the impact of serious deficiencies in Panama's counter-money laundering systems when dealing with transactions originating in, routed to, or involving entities or persons in Panama, particularly those involving large sums of money. Institutions subject to suspicious transaction reporting rules under 31 C.F.R. 103.18 should examine facts relating to transactions of $5,000 or more to determine if reporting is required. The Treasury Department will consider any report relating to a transaction described in this Advisory to constitute a report of a suspicious transaction relevant to a possible violation of law, providing protection from liability under 31 U.S.C. 5318(g)(2) and (g)(3).