In May, FinCEN issued FIN-2014-A005 regarding "funnel" accounts:

An account opened in one state (typically along the Southwest border) receives multiple cash deposits of less than $10,000 by unidentified persons at branches outside of the geographic region where the account is domiciled. The accounts receiving the outof- state deposits can be either individual or business accounts

Which helps explain why, in the previous February Chase revamped cash deposit rules In essence, the bank requires that any person making a cash deposit 1) be a signatory on the account and 2) provide identification.

Now, the recent influx of child migrants is tied to a law enforcement shift from AML to human smuggling, again connected to "funnel" accounts.

It's a "caution" to big banks with a big geographic footprint, particularly in a border state.



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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.