Non-Cooperative Countries and Territories

FinCEN conducted SAR research on the existing nine FATF designated NCCTs30 (as of June 2003) encompassing statistical data and ensuing trends from SARs filed on the NCCTs through December 2002. With the exception of Nauru and Guatemala, SAR filings increased for NCCTs after FATF designation. A common thread among these countries and the activities reported was suspicious and/or fraudulent wire transfer activity. With the exception of Nigeria, wire transfer activities accounted for the most prevalent description in the narratives for the ?BSA/Structuring/Money Laundering? violation and in the ?Other? violation category. A variety of scenarios accompanied this activity, including structured deposits followed by wire transfers; wire transfers followed by withdrawals in a foreign location via ATM or check; and use of a correspondent banking relationship with a U. S. bank, which was unable to verify a physical presence for the foreign bank. A number of other schemes were reported in the narratives, including Nigerian 419 scams; large cash payments ($9,900 to $20,000) on small or zero balance credit card accounts followed by ?Credit Balance Refund Checks? sent to account holders within days of the cash deposits; attempts to open accounts with invalid or altered identification documents; fraudulent letters of credit offered as security on loans in an alleged precious metals scam and in attempts to purchase securities. Possible direct or indirect connections with Internet gambling activities were reported, plus a scheme that involved the purchase of merchandise with counterfeit checks in amounts greater than the agreed upon purchase price, followed by wire transfer of the excess funds back to the customer before discovery of the counterfeit check(s).

Excerpted from SAR Activity Review Issue 6, page 68