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#2174258 - 04/19/18 03:16 PM How do I find this red flags list?
Anonymous
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Can anyone tell me how to navigate directly to this document, without already knowing the URL?

I think this may be a hidden link that can only be viewed if you happen to know the URL or have it saved.

https://www.ffiec.gov/bsa_aml_infobase/documents/red_flags/Money_Instru.pdf

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#2174259 - 04/19/18 03:17 PM Re: How do I find this red flags list? Anonymous
Anonymous
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OP here: Other questions of particular interest: What is its publication date? What document does it claim to be a part of? (It's curious the document has no footer identifying it as part of the FFIEC infobase, nor any indication of its publication or revision date.)

I ask because if this info was not online 4 years ago, that would make a world of difference.

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#2174264 - 04/19/18 03:42 PM Re: How do I find this red flags list? Anonymous
rlcarey Offline
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rlcarey
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It was created 05/04/2005

It has since been replaced with Appendix F: https://www.ffiec.gov/bsa_aml_infobase/pages_manual/OLM_106.htm
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#2174265 - 04/19/18 03:42 PM Re: How do I find this red flags list? Anonymous
Elwood P. Dowd Offline
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Elwood P. Dowd
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Next to Harvey
It's one of several listed on the FFIEC web site.

They are all older than dirt. wink
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#2174297 - 04/19/18 05:28 PM Re: How do I find this red flags list? Anonymous
Anonymous
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OP here: Replaced? But the new page you provide does NOT list those red flags. This could be very good/helpful news. Can you explain how you know it was replaced? Is there a trail showing the regulator pulled one list and replaced it with another?

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#2174299 - 04/19/18 05:32 PM Re: How do I find this red flags list? Elwood P. Dowd
Anonymous
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Originally Posted By Ken_Pegasus
It's one of several listed on the FFIEC web site.

They are all older than dirt. wink


OP here: Ken, how do I navigate to that without knowing the URL?

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#2174310 - 04/19/18 05:57 PM Re: How do I find this red flags list? Anonymous
rlcarey Offline
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Galveston, TX
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#2174369 - 04/19/18 08:47 PM Re: How do I find this red flags list? Anonymous
Anonymous
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OP: Thanks, Randy! FFIEC confirmed that the link I am asking about (https://www.ffiec.gov/bsa_aml_infobase/documents/red_flags/Money_Instru.pdf) is an older link that was replaced by Appendix F of the current version of the infobase, in 2014. (I believe it may have been replaced in the 2010 or 2011 updates, but 2014 is fine for my purposes here today.)

As near as I can determine, there is no series of clicks from Google or anywhere else that would lead me to that page from 2005 or whenever. It is not valid any more, because it was replaced. That's the stance I'll be taking.

The FFIEC could not explain to me how anyone could have navigated to that link without either a) knowing the URL somehow or b) having it cached or c) having it bookmarked.

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#2178302 - 05/16/18 02:17 PM Re: How do I find this red flags list? Anonymous
Anonymous
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OP here: Nevertheless, the examiners used that list against us and are continuing to use other links from the same obsolte "miscellaneous" page to allege we are missing SARs and have inadequate training! This is nuts. When we say, "That list was replaced a decade ago!" they don't care, they fall back on the SAR definition of "transaction without apparent business or lawful purpose" and keep plugging away at the lists. We got into a huge thing about one of these dumb miscellaneous lists that doesn't even apply anymore, and bowed down to their demands. Now they've just moved on to the second obsolete link.

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#2178303 - 05/16/18 02:20 PM Re: How do I find this red flags list? Anonymous
rlcarey Offline
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rlcarey
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Galveston, TX
Time to contact the supervisor in the head office or the ombudsman.
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