Anti-Money Laundering

Of a Chinese network supplying opioids to the US, FinCEN issued an advisory yesterday entitled “Advisory to Financial Institutions on Illicit Financial Schemes and Methods Related to the Trafficking of Fentanyl and Other Synthetic Opioids.” Here’s the first section (it’s a lengthy one – 18 pages):

Transnational criminal organizations (TCOs), foreign fentanyl suppliers, and Internet purchasers located in the United States engage in the trafficking of fentanyl, fentanyl analogues, and other synthetic opioids and the subsequent laundering of the proceeds from such illegal sales.


The Financial Crimes Enforcement Network (FinCEN) is issuing this advisory1 to alert financial institutions to illicit financial schemes and mechanisms related to the trafficking of fentanyl, fentanyl analogues, and other synthetic opioids,2 and to assist them in detecting and reporting related activity.

The United States is in the midst of an unparalleled epidemic of addiction and death, fueled by the illicit trafficking, sale, distribution, and misuse of fentanyl and other synthetic opioids. The statistics are sobering; between 2013 and 2017, deaths in the United States from synthetic opioids, other than methadone, increased over 800 percent.3 Every day in the United States, more than

130 people die from an opioid-related overdose.4 These numbers alone cannot fully capture the devastation wrought by this epidemic, the consequences of which are far reaching and everlasting, from grieving parents and orphaned children, to the enormous economic and public policy costs,5 and the destruction of current and future generations.

The epidemic is tearing away at the social and economic fabric of our communities, while TCOs, international drug traffickers, money launderers, and other criminal actors profit off the misery

of victims. Criminal networks and others generate billions of dollars in illicit drug proceeds, and

use the U.S. financial system and economy to advance their criminal enterprises and continue this epidemic to generate more criminal profits, resulting in more deaths and addictions. FinCEN

and other U.S. government agencies are collaboratively working with foreign partners, including Mexico, to end the fentanyl epidemic. This advisory will assist financial institutions in detecting

and reporting suspicious activity, making it harder and more costly for criminals to (i) commit these crimes; (ii) hide and use their illicit money; and (iii) continue fueling this epidemic. By using the information in this advisory and safeguarding our financial system, financial institutions will help save lives, protect innocent families, and ensure the safety and future of our communities. Indeed, this is the real value and utility behind information generated, maintained, and reported under the Bank Secrecy Act by financial institutions. This advisory highlights the primary typologies and red flags derived from sensitive financial reporting which are associated with (i) the sale of these drugs by Chinese, Mexican, or other foreign suppliers; (ii) methods used by Mexican and other TCOs to launder the proceeds of fentanyl trafficking; and (iii) financial methodologies associated with the sale and procurement of fentanyl over the Internet by purchasers located in the United States.6 Fentanyl is sold in the United States in many forms, all of which can be deadly. Fentanyl can be purchased alone; mixed with heroin, cocaine, or methamphetamine; or pressed into pill form and falsely sold as prescription opioids, many times being ingested by unsuspecting victims.


FinCEN Advisory

OFSI to update consolidated list links

In 2 weeks time, OFSI will update links to the consolidated list, the system it uses to publish the details of individuals and entities subject to financial sanctions.

The consolidated list extracts will have new updated links on the website. It is important that any bookmarks to the old links for each format are updated to the new links.

In addition to the existing five formats in which OFSI currently publishes the consolidated list (html, csv, xls, pdf and txt), it will now also be published as an .xml file. The files themselves will be updated as and when there are changes to the consolidated list and you will continue to be able to use the consolidated list as you do now.

There will also be a new search tool to help individuals and organisations identify targets of financial sanctions more easily. This allows users to quickly search the list of asset-freeze targets and the list of targets subject to restrictions on financial markets and services.

Further details will be published in the coming weeks. OFSI will be updating current links to the consolidated list on 30th August 2019. 

You’d think I wouldn’t have to write about how, if you don’t want to run afoul of US laws and regulations, you actually have to read them… but I did. I can’t tell you how many times, when I go overseas, I get complaints about how complex it all is.

Yeah, but… it is what it is.

The article touches on 3 sets of prominent examples: the CAPTA List, Section 311 of the USA PATRIOT Act and the Special Measures imposed by FinCEN, and the recent jostling over a subpoena issued to three Chinese banks (under the threat of penalties under Section 319 of the USA PATRIOT Act).

Read The Long Arm of the Law here… bottom line is that you can’t avoid the landmines if you don’t attempt to find where they are.

July 23, 2019
Contact: Bryan Hubbard
(202) 649-6870

OCC Issues Consent Order of Prohibition and $50,000 Civil Money Penalty Against Former General Counsel of Rabobank N.A.

WASHINGTON—The Office of the Comptroller of the Currency (OCC) today announced the issuance of a consent order of prohibition and $50,000 civil money penalty against Daniel Weiss, the former General Counsel of Rabobank, N.A., Roseville, Calif. (Bank).

The consent order prohibits Mr. Weiss from participating in the affairs of any federally insured depository institution and assesses a $50,000 civil money penalty for violations of law and unsafe or unsound practices alleged in the notice of charges (notice) issued on March 25, 2019.

The notice alleges that Daniel Weiss, as General Counsel of the Bank, participated in the continuous concealment of a third party report assessing the Bank’s Bank Secrecy Act program from the OCC in violation of 12 USC 481 and made false statements to the OCC in violation of 18 USC 1001.

On February 7, 2018, the Bank pled guilty to conspiracy to obstruct an OCC examination in violation of 18 USC 371 and 1517 in the U.S. District Court in the Southern District of California, and agreed to pay a forfeiture in the amount of $368,701,259 and a civil money penalty to the OCC in the amount of $50 million, based in part on the violation of 12 USC 481.


OCC Notice

Consent Order

Notice of Charges

FinCEN Exchange Forum Counters Business Email Compromise Scams

Steve Hudak, 703-905-3770
Immediate Release
Suspicious Activity Reports indicate more than $300 million a month in theft

WASHINGTON—The Financial Crimes Enforcement Network (FinCEN) today announced new efforts to curtail and impede Business Email Compromise (BEC) scammers and other criminals who profit from their schemes.  Email compromise fraud schemes generally entail criminal attempts to compromise the email accounts of victims to send fraudulent payment instructions to financial institutions or business associates in order to misappropriate funds or to assist in financial fraud.  Based on data from FinCEN’s Suspicious Activity Reports (SARs), hackers and other illicit actors’ BEC scams generated more than $300 million a month in 2018, with a cumulative total exceeding billions of dollars stolen from businesses and individuals.

“FinCEN has been a global leader and innovator in countering BEC breaches and their devastating effects on businesses, individuals, and national security,” said FinCEN Director Kenneth A. Blanco.  “The Bank Secrecy Act data is a critical resource in combatting all types of financial crime.  We hold, safeguard, and analyze that data and we share our expertise with law enforcement and our industry partners to help make America safer.”



FinCEN Exchange Forum Focuses on BEC Scams

In New York City today, FinCEN convened another in a series of meetings under its ongoing FinCEN Exchange forum.  Today’s focus was on identifying and combatting potential BEC and resultant money laundering and terrorist financing activities.  Representatives from depository institutions, Federal and State government agencies, a Federal task force, money transmitters, third-party service providers, and technology companies attended the session.  The FinCEN Exchange is a voluntary program established in 2017 to convene law enforcement and financial institutions from across the country to share information.


Advisory to Financial Institutions on E-mail Compromise Fraud Schemes

FinCEN also issued today an update to its “Advisory to Financial Institutions on E-mail Compromise Fraud Schemes,” first published in 2016.  Today’s advisory offers updated operational definitions, provides information on the targeting of non-business entities and data by email compromise schemes, highlights general trends in BEC schemes targeting sectors and jurisdictions, and alerts financial institutions to risks associated with the targeting of vulnerable business processes.  The advisory also highlights the potential for financial institutions to share information about subjects and accounts affiliated with email compromise schemes in the interest of identifying risks of fraudulent transactions and money laundering.


Financial Trend Analysis of Bank Secrecy Act (BSA) Data

In addition, FinCEN issued an in-depth Financial Trend Analysis of BSA data that explores industries targeted and methodologies used by BEC scammers.  It notes that the number of SARs describing BEC incidents reported monthly has more than doubled, from averaging nearly 500 per month in 2016, to above 1,100 per month in 2018.  The total value of attempted BEC thefts reported in SARs has almost tripled, to an average of $301 million per month in 2018 from $110 million per month in 2016.  The use of fraudulent vendor or client invoices grew as a methodology, from 30 percent of sampled 2017 incidents, to 39 percent in 2018, becoming the most common BEC method.  Impersonating a CEO or other high-ranking business officer as a methodology declined, accounting for 12 percent in 2018 from 33 percent of sampled incidents in 2017.  Impersonation of an outside entity was described in 20 percent of 2018 reports.  Manufacturing and construction businesses were the top targets for BEC fraud in 2017 and 2018, and those sectors may have particular interest in this report.


FinCEN’s Rapid Response Program Surpasses $500 Million in Recovered Funds

In another ongoing effort, FinCEN’s Rapid Response Program, in collaboration with law enforcement, recently surpassed $500 million in recovered funds.  Under the program, when U.S. law enforcement receives a BEC complaint from a victim or a financial institution, the relevant information is forwarded to FinCEN, which moves quickly to track and recover the funds.  The program utilizes FinCEN’s ability to rapidly share information with counterpart Financial Intelligence Units (FIU) in more than 164 jurisdictions, and leverages these relationships to encourage foreign authorities to intercede and hold funds or reverse wire transfers.


Egmont Group Public Bulletin Outlines Typologies of BEC Fraud Schemes

In addition, yesterday, the Egmont Group of FIUs issued a public bulletin to alert competent authorities and reporting entities of key typologies and money laundering risks associated with BEC fraud schemes.  This bulletin was the result of an initiative by FinCEN and the FIU of Luxembourg in collaboration with nine other FIUs.

Sharing information through reports and public-private partnerships supports more, and higher-quality, reports to FinCEN and assists law enforcement in detecting, preventing, and prosecuting terrorism, organized crime, money laundering, and other financial crimes.  Sharing information also assists the financial institutions in prioritizing their efforts.  One of FinCEN’s top priorities is strengthening public-private partnerships to reveal and mitigate threats and vulnerabilities in the U.S. financial system.


FinCEN Press Release

FinCEN Advisory

Financial Trend Analysis

Advisory on the Financial Action Task Force-Identified Jurisdictions with Anti-Money Laundering and Combating the Financing of Terrorism Deficiencies and Relevant Actions by the United States Government

The Financial Crimes Enforcement Network (FinCEN) is issuing this advisory to inform financial institutions of updates to the FATF list of jurisdictions with strategic AML/CFT deficiencies. Financial institutions should be aware of these changes, which may affect their obligations and risk-based approaches with respect to these jurisdictions. The advisory also reminds financial institutions of the status and obligations involving these jurisdictions, in particular the Democratic People’s Republic of Korea (DPRK) and Iran.

As part of the FATF’s listing and monitoring process to ensure compliance with its international AML/CFT standards, the FATF identifies certain jurisdictions as having strategic deficiencies in their AML/CFT regimes.1 These jurisdictions are named in two documents: (1) the “FATF Public Statement,” which identifies jurisdictions that are subject to the FATF’s call for countermeasures and/or enhanced due diligence (EDD) because of their strategic AML/CFT deficiencies; and (2) “Improving Global AML/CFT Compliance: On-going Process,” which identifies jurisdictions that the FATF has determined to have strategic AML/CFT deficiencies.2 On June 21, 2019, the FATF updated both documents. Financial institutions should consider these changes when reviewing their obligations and risk-based policies, procedures, and practices with respect to the jurisdictions noted below.3

The advisory then continues with specific sections on Iran and the DPRK, as well as the countries subject to FATF’s ongoing monitoring program. In this second category, Panama was added to the list of jurisdictions and Serbia was no longer subject to ongoing monitoring.

The document also contains reviews of Section 312 guidance, including a specific section for Iran and North Korea, a review of the guidance of the jurisdictions on FATF’s ongoing monitoring list, and a reminder to use the SAR form that was updated in February of this year.


FinCEN Advisory

July 2019


This operational brief provides information and guidance about the factors that expose individuals and entities (both retailers and wholesalers/suppliers) that are dealers in precious metals and stones to money laundering and terrorist financing risks. The brief also includes indicators to help such dealers determine when they should report a suspicious transaction to the Financial Transactions and Reports Analysis Centre of Canada (FINTRAC).


Dealers in precious metals and stones (DPMS) have a unique risk profile with regard to money laundering and terrorist financing because they trade in transferable items of value. This risk is heightened because these items could be one or more of the following:

  • the proceeds of crime

  • purchased with the proceeds of crime

  • used to launder the proceeds of crime.

This brief aims to identify possible money laundering and terrorist financing activities and assess the risks DPMS face.

As part of Canada’s anti-money laundering and anti-terrorist financing efforts, DPMS must understand their obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its associated Regulations. 

When DPMS carry out purchases or sales, and the value of a single transaction is $10,000 or more, they become what are known as “designated reporting entities” under the Act. This means they have to file a report with FINTRAC in the following circumstances:

  • they receive CAN$10,000 or more in cash, or they receive two or more cash amounts of less than $10,000 each that total $10,000 or more within 24 consecutive hours, from or on behalf of the same individual or entity

  • they know that property in their possession or under their control is owned by, or is controlled by or on behalf of, a terrorist or a terrorist group

  • they have reasonable grounds to suspect that a transaction or an attempted transaction is related to the commission or attempted commission of a money laundering or terrorist financing offence.

In addition, all DPMS must have policies and procedures in place to determine when transactions pose a high-risk for money laundering or terrorist financing. This is accomplished by creating an effective compliance program and a documented risk assessment approach, including mitigation measures and strategies. To ensure DPMS are meeting the requirements of the Act and associated Regulations, FINTRAC conducts on-site and office examinations, measuring DPMS’s compliance and risk assessment activities against the requirements set out in operational briefs and other sources of information.

FINTRAC’s website contains detailed guidance on the legal obligations of DPMS under the Act.

Identifying money laundering and terrorist financing risks

There are five areas that DPMS should be aware of when assessing their risk of being exploited for money laundering or terrorist financing:

  • their products, services and delivery channels

  • their clients and business relationships, including clients’ activity patterns and geographic locations

  • the geographic location where they do business

  • new technologies

  • other relevant factors affecting their business.

Products, services and delivery channels

DPMS offer unique products and services to the marketplace. In turn, each product and service involves unique money laundering and terrorist financing risks.

Gold, for instance, can be of considerable value and have considerable liquidity—that is, it can be converted to cash relatively easily at near-purchase value. As another example, individuals can purchase, transfer or store some types of jewellery, diamonds, gold bars and other precious metals and stones more easily than bulk cash.

Accordingly, dealers are at risk for being exploited for money laundering or terrorist financing due to the following attributes associated with precious metals and stones:

  • Liquidity: This is the degree to which a product can be sold for near-purchase price. Higher liquidity means a higher risk for money laundering or terrorist financing. For example, gold has very high liquidity, while most finished jewellery does not.

  • Market size: A larger market makes it easier to convert a product into cash or other financial instruments, and thus presents a higher risk for money laundering or terrorist financing.

  • Product value: The higher the value of the product, the more attractive it is to criminals; therefore, the risk of money laundering or terrorist financing increases.

  • Product size/mass: The larger the product, the harder it is to transport and/or store, which reduces the risk of money laundering or terrorist financing. For example, lower quality or unrefined stones, which are larger or heavier than their value would suggest, present less risk for money laundering or terrorist financing than do higher quality stones.

  • Ability to store/transfer: The easier it is to store or transport a product, the higher risk it presents for money laundering or terrorist financing. Some contributing characteristics are the durability of the product, the ease of detecting the product and the changeability of the product.

When conducting transactions, DPMS must consider these attributes in conjunction with the other money laundering risks described in this brief.

DPMS must also consider their service delivery channels. Transactions not conducted face to face present greater money laundering or terrorist financing risk, particularly when products are shipped to post office boxes or international addresses.

Clients and business relationships, including activity patterns and geographic locations

When assessing the money laundering and terrorist financing risks transactions pose, DPMS must consider how clients present themselves and conduct transactions.

Dealing in large amounts of cash brings significant money laundering and terrorist financing risks with it, and these risks can extend beyond receiving cash as payment in a single transaction. For example, clients can make cash payments against layaway plans in an attempt to structure transactions and avoid reporting requirements. This makes DPMS vulnerable to exploitation over the life of the plans.

Transaction activity related to layaway plans may be subject to the large cash reporting requirement under the Act. When DPMS receive $10,000 or more in cash within a 24-hour period from or on behalf of the same person or entity, they must file a large cash transaction report with FINTRAC. When it appears that cash payments are being split up to avoid this type of reporting, DPMS should file a suspicious transaction report with FINTRAC.

At the same time, dealers should not assume that non-cash transactions are “clean,” since illicit funds could have been placed into the financial system prior to the transactions taking place. Other financial instruments may present lower money laundering or terrorist financing risk than cash, but the risk nevertheless exists and varies between instruments. For example, bank drafts present more risk than cheques because they are not linked to an account and its associated customer due diligence, while cheques are linked to an account.

When customers use other payment methods, such as wire transfers, credit cards or cheques, DPMS should consider whether transactions are in line with what is known about the customer and whether they are normal in the context of their dealings with those customers. For example, individuals who have made arrangements to ensure their anonymity, such as purchasing through shell companies, present a risk for money laundering or terrorist financing, since this is not a normal business practice. A purchase or a series of purchases outside of the apparent means of a client should be considered when assessing the money laundering or terrorist financing risk the client presents.

Geographic locations where dealers do business

DPMS must consider the location of their business, and how that affects their money laundering and terrorist financing risks. In particular, DPMS must evaluate the following characteristics:

  • Where the business is located

    • whether they are located in a high-crime area or low-crime area

    • whether they are located in a rural area, where clients may be known to them, or do business in a large city, where new clients and anonymity are more likely

    • whether they see very-high-volume sales relative to the apparent financial standing of their surroundings

    • whether the business is close to a border crossing, since this could increase risk (businesses so located may be the first point of entry into Canada’s financial system).

  • Where the business is conducting transactions

    • whether the business operates with a storefront only, online only or through a mix of locations and platforms

    • whether the business conducts transactions with foreign clients based in countries subject to sanctions, embargoes or other measures (these transactions should be considered high-risk).

  • Where the business’s inventory is sourced from

    • whether sellers are well known to the business, or the business works with a variety of providers

    • whether the business has inventory or works with sellers in jurisdictions of concern.

New technologies

DPMS must also consider whether their business is exposed to incremental money laundering and terrorist financing risks as a result of new technologies that their customers are using to pay for products or that they themselves are using to sell them. New technologies differ from product to product; however, some offer benefits to potential money launderers and terrorist financiers, including enhanced anonymity, quicker transactions and transactions outside of the financial system covered by anti-money laundering and anti-terrorist financing regulations.

Over the past several years, FINTRAC has noted an increased prevalence of new technologies in its suspicious transaction reports and disclosures of money laundering and terrorist financing activities to law enforcement. Virtual currencies, email money transfers and payment processors in particular have increased in prominence in FINTRAC’s reporting.

Other relevant factors affecting the business

Finally, DPMS must consider other potentially relevant risk factors that may be affecting their risk level, and the risk level of customers, for money laundering and terrorist financing:

  • Elements of the DPMS’s structure: Entities with a high turnover of staff may present greater risks for money laundering and terrorist financing, since their staff may be less likely to be able to recognize potential red flags. Additionally, entities that operate solely in one location have significantly different risks than entities that are part of a chain with many locations.

  • Use of intermediary agents: The use of intermediary agents to conduct transactions may present a higher risk. Entities should consider the transactions’ appropriateness, necessity and normalcy.

  • Barriers to entry: For parts of the industry with higher barriers to entry, such as specialized licences to sell, the money laundering and terrorist financing risks may be lower, since criminals may have a harder time infiltrating these markets.

  • Trends, typologies and potential threats of money laundering and terrorist financing:When DPMS are dealing with clients for whom there are observable trends and/or typologies of money laundering and terrorist financing, they should review FINTRAC’s Suspicious Transaction Guidance and Strategic Intelligence to determine whether these clients present a higher risk for money laundering or terrorist financing.

Risk mitigation: Risk-based approach and effective compliance program

FINTRAC published a comprehensive risk-based approach workbook on how DPMS can mitigate their risk of exploitation for money laundering or terrorist financing. This workbook is structured to help dealers identify the risks associated with products, services and delivery channels; clients and business relationships; and geography, as it relates to both clients and the location of their own business.

In addition to taking a risk-based approach, DPMS must put a comprehensive and effective compliance program in place to meet all their reporting and other obligations under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (e.g. client identification and record-keeping).

Indicators of suspicious transactions

FINTRAC has developed indicators of suspicious transactions based on key factors related to retail and wholesale/supplier DPMS. These indicators detail situations and/or transactions in which DPMS are at an increased risk to be exploited for money laundering or terrorist financing, such that further assessment of these transactions may be required to appropriately mitigate the risk.

The indicators that follow are intended to help DPMS assess whether there may be reasonable grounds to suspect that a transaction, or attempted transaction, is related to the commission of a money laundering or terrorist financing offence. DPMS should use these indicators in conjunction with other published indicators, such as those contained in FINTRAC’s Money Laundering and Terrorist Financing Indicators Guidance for DPMS. In addition, FINTRAC’s Suspicious Transaction Guidance provides key considerations for determining whether DPMS should submit a suspicious transaction report to FINTRAC.

Retail indicators

(T for transactional indicators and B for behavioural indicators)

The individual appears to be structuring amounts to avoid customer identification or reporting thresholds.


The individual frequently uses layaway plans in an apparent attempt to avoid reporting requirements (also known as structuring). 


The individual uses a payment card that appears to be altered or stolen. 


The individual buys high-value goods using small-denomination bills ($5, $10, $20). 


The individual sells gold in non-standard bricks or similar shapes with no distinct markings or value.


The individual will only trade items for cash or other precious metals and stones.


The individual attempts to buy precious metals or stones with a company credit card or a credit card not in their name. 


The individual trades items for similar items of near-equal value.


The individual uses negotiable instruments or credit cards issued in a country other than Canada to make purchases.


The individual frequently crosses the Canada-U.S. border to buy jewellery or precious metals, in particular where there is not a strong economic incentive to do so. 


The customer or supplier attempts to maintain a high degree of secrecy with respect to the transaction, such as requesting that normal business records not be kept.


The individual makes large or frequent purchases in funds other than Canadian dollars.


The individual appears to be living beyond their means. 


The transactional activity (level or volume) is inconsistent with the individual’s apparent financial standing, their usual pattern of activities or occupational information (e.g. student, unemployed, social assistance).


The individual cannot explain the origin of the precious metals and stones.


The individual is willing to sell items at rates significantly lower than their typical sale value. 


The individual appears to be uninterested in the details of the sale or purchase of goods, which would normally be material information for a client.


The individual indiscriminately purchases merchandise without regard for value, size or colour. 


The individual is vague or refuses to provide details about why they are selling or buying items, or about the origin of the items.


The individual uses alternative addresses for deliveries, uses post office boxes or uses third parties to receive purchases.


Multiple individuals are involved in retrieving, transporting or purchasing items. 


The individual does not wish to buy or sell face to face and is nervous about information related to their identification. 


The individual attempts to purchase abnormally large quantities of precious metals or loose jewels in non-wearable form. 

Wholesale/supplier indicators

(T for transactional indicators and B for behavioural indicators)

The individual or entity appears to be structuring amounts to avoid customer identification or reporting thresholds.


The individual or entity pays for high-priced jewellery or precious metals with cash only.


The individual or entity pays for purchases through a lawyer’s trust account.


The individual or entity pays for expensive purchases exclusively with cryptocurrency, especially when buying gold stored by a wholesaler or supplier. 


The individual or entity uses financial instruments from a foreign bank and/or that are not in Canadian dollars.


The individual or entity amasses a large amount of stored bullion or precious stones over time, in an apparent attempt to avoid reporting requirements (known as structuring).  


The individual’s or entity’s listed address is in a high-risk jurisdiction known for corruption or smuggling relating to precious metals or stones. 


The individual or entity sells a large amount of precious metals and stones that originate or are known to be traded from areas not known for their production (i.e. trading centres).


The individual or entity amasses a large amount of precious metals or stones in a wholesaler’s or supplier’s storage facility or pool over time.


The entity’s ownership structure appears invalid or altered, or the entity refuses to provide additional information when requested.


The individual benefiting from the purchase cannot be identified.


The location to which bullion or stones are moved directly to or from storage is different from the individual’s or entity’s listed address.


The individual or entity continually moves large volumes of bullion directly into and out of storage.


The individual provides only a non-civic address such as a post office box, or disguises a post office box as a civic address for the purpose of concealing their physical residence. 


The individual or entity does not appear to understand the precious metals and stones industry, or lacks the appropriate equipment or finances to engage in activity in that industry. 


The individual appears to be uninterested in or uninformed about the structure or transactions of their business. 


The size or type of transactions is atypical for the individual or entity.


The customer or supplier attempts to maintain a high degree of secrecy with respect to the transaction, such as requesting that normal business records not be kept.


FINTRAC Operational brief – HTML, PDF