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FinCEN Advisory: Recognizing and Reporting Suspicious Transactions Involving North Korea

The Financial Crimes Enforcement Network (FinCEN) has issued an advisory to financial institutions on identifying and reporting suspicious transactions related to North Korea. This document provides guidance on a risk-based approach to preventing such transactions.

Key Points from the Advisory

Risk-Based Approach

Financial institutions must take a risk-based approach when deciding what due diligence measures to adopt to prevent North Korea-related transactions.
This means evaluating the level of risk associated with each transaction and taking steps accordingly to mitigate that risk.

Notification of Correspondent Account Holders

If a financial institution knows or has reason to believe that a correspondent account is being used for North Korea-related transactions, it must notify the account holder and take steps to further investigate and prevent such access.
This includes providing clear information about the reasons for the notification and any subsequent actions taken.

Suspicious Activity Reporting (SAR)

Financial institutions should file a SAR if they know, suspect, or have reason to suspect that a transaction has no business or apparent lawful purpose or is not the sort in which the particular customer would normally engage.
This includes transactions that may be related to North Korea’s illicit finance activities.

Red Flags

The presence or absence of a red flag in any given transaction is not by itself determinative of whether a transaction is suspicious.
Financial institutions should consider evaluating indicators of potential North Korea-related illicit activity in combination with other red flags and factors before making determinations of suspiciousness.

Using Previous FinCEN Advisories

Financial institutions are encouraged to use previous FinCEN advisories as references when evaluating potential suspicious activity.
This can help provide additional guidance on identifying and reporting suspicious transactions related to North Korea.

Financial institutions may want to consider sharing information with one another, as appropriate, either for the purposes of filing a joint SAR or under Section 314(b) of the USA PATRIOT Act.
This can facilitate the exchange of information between financial institutions and help prevent North Korea-related illicit finance activities.