[12305]
July 19, 2000
TO: BANK AND TRUST ADVISORY COMMITTEE No. 17-00
BROKER/DEALER ASSOCIATE MEMBERS No. 9-00
COMPLIANCE ADVISORY COMMITTEE No. 26-00
INTERNATIONAL MEMBERS No. 11-00
SEC RULES MEMBERS No. 47-00
TRANSFER AGENT ADVISORY COMMITTEE No. 33-00
RE: FINCEN RELEASES MONEY LAUNDERING ADVISORIES
Last week, the US Department of the Treasury’s Financial Crimes Enforcement Network
(FinCEN) released advisories relating to fifteen countries because of weaknesses in their anti-money
laundering regimes.1 The advisories were issued to inform US banks and other financial institutions,
including investment companies and broker-dealers, of the “serious deficiencies” in the counter-money
laundering systems of these countries.
FinCEN recommends that all US banks and other financial institutions should carefully consider,
when dealing with transactions originating in or routed to or through these countries, or involving entities
organized or domiciled or persons maintaining accounts in these countries, how the deficiencies in the
counter-money laundering controls affect the possibility that those transactions are being used for illegal
purposes. Copies of the advisories are available on the Institute’s members’ website at
http://members.ici.org2 and the FinCEN web site at http://www.treas.gov/fincen.
In considering the FinCEN advisories and reviewing their own counter-money laundering
policies and procedures, Institute members may want to refer to the Institute’s compliance paper “Money
Laundering Compliance for Mutual Funds.”3
Robert C. Grohowski
Assistant Counsel
1 The advisories relate to the Bahamas, the Cayman Islands, the Cook Islands, Dominica, Israel, Lebanon, Liechtenstein, the
Marshall Islands, Nauru, Niue, Panama, the Philippines, Russia (the Russian Federation), St. Kitts & Nevis, St. Vincent & the
Grenadines.
2 The members' website is password-protected; staff at Institute member firms may request access codes by filling out the
enrollment form on the website.
3 Investment Company Institute, Money Laundering Compliance for Mutual Funds (May 1999). This paper is available on the
Institute’s members’ website at http://members.ici.org.