Here is a list we used in the beginning:
High-Risk” Examples include:
Businesses
 Nontraditional financial entities, such as:
 Currency exchange houses, also known as giros or casas de cambio.
 Money transmitters.
 Check cashing facilities.
 Casinos and card clubs.
 Offshore corporations and banks located in tax and/or secrecy havens.
 Leather goods stores.
 Car, boat, and plane dealerships.
 Used automobile or truck dealers and machine parts manufacturers.
 Travel agencies.
 Brokers/dealers.
 Jewel, gem, and precious metal dealers.
 Import/export companies.
 Auctioneers.
 Deposit brokers.
 Pawn brokers.
 Professional service providers (lawyers, accountants, investment brokers).
 Cash-intensive businesses, such as convenience stores, restaurants, retail stores, and parking garages.
 Ship, bus, and plane operators.
 Telemarketers.
Banking functions and transactions
 Private banking.
 Trust departments.
 Offshore international activity.
 Deposit-taking facilities.
 International correspondent banking activity.
 Internet banking.
 Wire transfers/cash management functions.
 Transactions in which the primary beneficiary or counterparty is undisclosed.
 Loan guarantee schemes.
 Transactions involving large amounts of traveler’s checks, official bank checks, money orders, and stored value cards.
 Pouch activity.
 Electronic transactions that permit the rapid movement of currency (e.g., foreign exchange transactions followed by payment into another jurisdiction).
 Trade financing transactions with unusual pricing features.
High-Risk Countries
 Countries in which the production or transportation of illegal drugs may be taking place.
 Bank secrecy havens.
 Emerging countries that may be seeking hard currency investments.
 Countries identified in FinCEN advisories.
 Major money laundering countries and jurisdictions.