The term “shell company” refers to non-publicly traded corporations, LLCs, and trusts that are physically located outside the U.S.

Banks offering account services to processors should assess the risks associated with these customers, by considering the following:

Embassy, foreign consulate, and foreign mission accounts may pose a higher risk in the following circumstances:

An intermediary bank is unable to monitor or filter payment information when SWIFT messages for funds transfers are received without adequately completed MT 103 or MT 202 COV data.

Banks are required to investigate suspected underlying crimes on which they file SARs.

When considering an institution’s geographic money laundering risk factor, countries sanctioned by OFAC are only important to a US financial institution

Training should encompass information related to applicable business lines, as well as changes to internal policies, procedures, processes, and monitoring systems.

When structuring the BSA/AML compliance function, authority and independence are not of interest

Consolidated information assists senior management and the board of directors in understanding and appropriately mitigating risks across the organization.

Given that e-banking transactions are processed through high levels of technology they need not be subjected to EDD