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OCC Bulletin 2006-30 | July 19, 2006

Bank Secrecy Act/Anti-Money Laundering: FinCEN Guidance to Financial Institutions on the Repatriation of Currency Smuggled into Mexico from the United States


Chief Executive Officers, BSA Officers, and Compliance Officers of All National Banks; All Department and Division Heads; and All Examining Personnel

The Financial Crimes Enforcement Network (FinCEN) issued the attached advisory to U.S. financial institutions so that they may better guard against an increasingly prevalent money laundering threat involving the smuggling of bulk U.S. currency into Mexico. The advisory warns U.S. financial institutions of the potential misuse of relationships they may have with certain Mexican financial institutions, including Mexican casas de cambio. U.S. financial institutions should take reasonable steps to raise their guard against abuse of their financial services by these entities, especially because once the U.S. currency is in Mexico, numerous layered transactions may be used to disguise its origins, after which it may be returned directly to the United States or further transshipped to or through other jurisdictions. This advisory is consistent with the U.S. Department of the Treasury's efforts to ensure that U.S. financial institutions are not used as a conduit for the laundering of proceeds from narcotics trafficking.

U.S. law enforcement has observed a dramatic increase in the smuggling from the United States into Mexico of bulk cash proceeds derived from the sale of narcotics and other criminal activities. Bulk cash smuggling often increases in response to successful efforts by U.S. financial institutions and U.S. law enforcement to shut down available avenues for narcotics traffickers to place illicit currency proceeds directly into U.S. financial institutions. FinCEN, in conjunction with the Department of the Treasury and other federal agencies, has identified in this advisory activities that may be associated with the current currency-smuggling trend. While this advisory has been issued to assist U.S. financial institutions in complying with their obligations under the Bank Secrecy Act, FinCEN emphasized that the issuance of this advisory does not mean that U.S. financial institutions should curtail business with legitimate currency exchangers or other money services businesses.

To view the advisory, select the link below. You may direct questions to your supervisory office or to the Compliance Policy Department at (202) 649-5740.

Ann F. Jaedicke
Deputy Comptroller for Compliance Policy

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