The fight against money laundering and terrorist financing in the U.S. is an ongoing and evolving battle. That’s why every year FinCEN produces a new National Money Laundering Risk Assessment from the Department of the Treasury. In an analysis of more than 5,000 law enforcement cases and financial reports from both the private and government sectors, the 2015 Risk Assessment exposes trouble spots and emerging trends all financial institutions should analyze.

The global dominance of the U.S. dollar generates trillions of dollars of daily transaction volume through U.S. financial institutions, creating significant exposure to potential money laundering activity. Although the U.S. has implemented a robust set of anti-money laundering rules designed to hinder criminals, criminals are resourceful. They continue to look for new vulnerabilities and methods to mask their identities and systems.

Once illicit proceeds are placed into the financial system, the continued use of financial institutions to move those funds both domestically and internationally can further obscure their criminal origins and facilitate their integration into the system. Therefore, establishing and maintaining an effective customer identification program is a key control.

Financial institutions are put in a vulnerable position when individuals and entities attempt to disguise the nature, purpose, or ownership of their accounts. This can occur through several avenues, but we’ll address the top three…

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