The Financial Crimes Enforcement Network (“FinCEN”) has issued a Notice on the Use of Counterfeit U.S. Passport Cards to Perpetrate Identity Theft and Fraud Schemes at Financial Institutions (“Notice”), asking financial institutions (“FIs”) to be vigilant in identifying suspicious activity relating to the use of counterfeit U.S. passport cards.  According to the Notice, the U.S. Department of State’s Diplomatic Security Service (“DSS”) has determined that there is a growing use of such counterfeit cards to gain access to victim accounts at FIs.  “This fraud occurs in person at [FIs] and involves an individual impersonating a victim by using a counterfeit U.S. passport card that contains the victim’s actual information.”

As its title plainly states, the Notice pertains to passport cards, rather than passport books.  Passport cards have more limited uses and can be used only for land, sea and domestic air travel into the U.S. from Canada, Mexico, the Caribbean and Bermuda.  The following graphic from the Department of State illustrates the difference. 

The Notice observes that FIs are less likely to detect fraud involving passport cards because they are a less familiar form of U.S. government-issued identification.  Victims’ personal identifiable information (“PII”) is typically acquired through the darknet or the U.S. mail (see our blog post on the surge in mail-theft check fraud here).  After a fake card is created, the illicit actor or complicit money mule will visit a branch of the victim’s FI – often by trying to avoid any branches that the victim actually may visit, so as to reduce the chances of detection.

Continue Reading  FinCEN Issues Notice on Counterfeit Passport Card Fraud

Twelve minutes ahead of the deadline set by Congress back in August, the U.S. Treasury Department issued a highly anticipated report listing Russian oligarchs and senior political figures.  That sound you heard at 11:48 last night?  A host of wealthy Russians heaving sighs of relief.

The “Countering America’s Adversaries Through Sanctions Act,” (CAATSA) which was passed with overwhelming bipartisan support last summer, instituted new sanctions against Russia related to its interference with Ukraine and its alleged tampering with the 2016 presidential election.

But it also required the Treasury Department to issue, no later than yesterday, a report identifying Russian oligarchs with close ties to Vladimir Putin. The report was to identify “the most significant senior political figures and oligarchs in the Russian federation . . . as determined by their closeness to the Russian regime and their net worth.”  The report was required to detail the relationship between identified oligarchs and President Vladimir Putin or “other members of the Russian ruling elite,” “any indices of corruption with respect to those individuals, “their net worth and known sources of their (and their families’) income, and the non-Russian business affiliations of those individuals.”

In addition to reporting on individuals, the report was to identify “Russian parastatal entities,” their leadership structures and beneficial ownership, and the scope of their non-Russian business affiliations.
Continue Reading  Nothing to See Here:  Treasury Report Naming Russian Oligarchs Rehashes Old News and Provides No New Sanctions

The Philippines has been identified by the U.S. as a “major money-laundering country” in the 2017 International Narcotics Control Strategy Report (“Report”), published this month. The country now joins 87 others as one “whose financial institutions engage in currency transactions involving significant amounts of proceeds from international narcotics trafficking.” See 22 U.S.C. § 2291(e)(7).

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