AL 2003-5
Advisory Letter

Subject:  U.S. Department of Treasury FinCEN Advisory 2W

Date:     June 24, 2003

TO:   Chief Executive Officers and Compliance Officers of National 
      Banks and Federal Branches, Department and Division Heads, and 
      Examining Personnel

This advisory letter revises the list of countries detailed in OCC 
Advisory Letter (AL) 2003-4, “U.S. Department of Treasury FinCEN 
advisories 16W and 31W,” dated May 16, 2003 (see also AL 2002-10, 
AL 2002-7, AL 2002-5, AL 2002-2, AL 2001-7, and AL 2000-8). 

In March 1996, the U.S. Department of the Treasury’s Financial Crimes 
Enforcement Network (FinCEN) issued Advisory 2 identifying the 
Republic of Seychelles as a safe haven for the proceeds of drug 
trafficking and other crimes.  Subsequently, in July 2000, FinCEN 
issued a series of advisories identifying 15 countries with serious 
deficiencies in their counter-money-laundering systems.  [See FinCEN 
advisories 13 - 27 (July 2000).  The FinCEN advisories are available 
at www.treas.gov/fincen and additional guidance is provided in the 
OCC’s AL 2000-8.]  Since then, FinCEN has issued additional 
advisories eliminating or revising some of those original advisories 
[See OCC advisory letters 2001-7, 2002-2, 2002-5, 2002-7, and 
2002-10; or FinCEN advisories 2W, 11A, 13A, 14A, 16W, 17A-23A, 25A, 
26A, and 31W.]. 

The attached FinCEN Advisory 2W withdraws FinCEN Advisory 2 regarding 
the Republic of Seychelles.  Enhanced scrutiny of transactions with 
the Seychelles is no longer necessary due to actions taken by the 
Seychelles that strengthened its counter-money-laundering system.  
The FinCEN advisory is consistent with the Financial Action Task 
Force on Money Laundering decision to withdraw its February 1, 1996, 
warning regarding the Seychelles.  

FinCEN advisories remain in effect for the following jurisdictions 
[See FinCEN advisories 15, 21, 21A, 24, 27-30, and 32.]:

·  The Arab Republic of Egypt,
·  Burma,
·  The Cook Islands,
·  The Federal Republic of Nigeria,
·  Nauru,
·  The Philippines,
·  St. Vincent and The Grenadines, and
·  Ukraine.

The FinCEN advisories on the above jurisdictions emphasize the need 
for enhanced scrutiny of certain transactions and banking 
relationships in these jurisdictions to ensure that appropriate 
measures are taken to minimize risk for money laundering.  Please 
refer to OCC AL 2000-8 for additional information on banking 
relationships in the subject jurisdictions.  Also, refer to the 
Bank Secrecy Act/Anti-Money Laundering booklet in the Comptroller’s 
Handbook and OCC advisory letter, AL 2000-3, for guidance on 
controlling risk of money laundering.  Copies of the booklet and the 
OCC advisory letters are available at 
[www.occ.treas.gov/handbook/bsa.pdf] and 
[www.occ.treas.gov/issue.htm].

If you have any questions please contact your supervisory office or 
the Compliance Division at (202) 874-4428.




__________________
David G. Hammaker
Deputy Comptroller for Compliance

Attachment: FinCEN Advisory 2W

Can also be found electronically at:
[http://www.fincen.gov/pub_main.html]