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#2270327 - 05/11/22 06:00 PM International Debit Card Activity
ComplyGuy Offline
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Joined: May 2015
Posts: 245
We've identified some questionable activity in our institution related to ATMs and debit cards used internationally.

Situation is basically that a customer has an account based in the United States. Deposits are being made by multiple methods, cash/check. But, a debit card is being used in a foreign country at ATMs making cash withdrawals. In some instances it is a joint account owner in the foreign country, but other times not. The amounts are typically small (1-2k/month), but still seems questionable.

It is my first time seeing this type of activity that was identified by our new AML monitoring system. Wondering if others have thoughts or ideas regarding these situations if you've seen them before. Should we prohibit this activity? Is it suspicious?

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#2270338 - 05/11/22 07:16 PM Re: International Debit Card Activity ComplyGuy
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What foreign countries are you seeing the withdrawals in? We had a situation where some actors opened accounts and deposited small amounts of cash, maybe $2M-$3M a week and the funds were almost immediately withdrew in Ukraine. We shut them down and showed them the door.

We have other examples where funds are deposited in the US and cash is withdrawn in the EU and we generally have no issue with this. This could be vacation, kids studying abroad, someone who has a second home abroad, etc.

You will need to chat with your customer(s) to get more information to see if you should be concerned or not.
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#2270346 - 05/11/22 07:51 PM Re: International Debit Card Activity ComplyGuy
ComplyGuy Offline
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Joined: May 2015
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Appreciate the perspective. Also realized I forgot to logout before posting, oh well.

Our situation seems to be much more consistent than a vacation. Turkey and Mexico are a couple of the countries. It appears that someone is permanently in the foreign country using the card on a regular basis while others are in the US.

But we will need to follow up and try to get more information.

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#2270350 - 05/11/22 08:20 PM Re: International Debit Card Activity ComplyGuy
ACBbank Online
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New York City
Based on those jurisdictions, I would be reaching out to your client(s) for additional answers.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#2270366 - 05/12/22 02:40 PM Re: International Debit Card Activity ComplyGuy
rlcarey Offline
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rlcarey
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Galveston, TX
Is the joint accountholder a foreign national?
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#2270421 - 05/13/22 04:13 PM Re: International Debit Card Activity rlcarey
ComplyGuy Offline
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Originally Posted by rlcarey
Is the joint accountholder a foreign national?
I believe they are. How would that impact your thoughts on the situation?

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#2270423 - 05/13/22 04:27 PM Re: International Debit Card Activity ComplyGuy
BrianC Offline
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Joined: Nov 2004
Posts: 6,238
Illinois
It's really a business decision whether you permit the activity or not. It's not uncommon for immigrants to send an ATM card to family members back home as this method is likely less expensive than funds transfers via Western Union, Moneygram, Envios, etc. If it is not a joint account owner in possession if the card, you have the potential risks of providing services to an unknown individual which increases OFAC risk, fraud risk, etc.

Mary Beth Guard referred to these unknown persons as "Ghost customers" at a Top Gun presentation many moons ago.
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#2270443 - 05/13/22 10:12 PM Re: International Debit Card Activity ComplyGuy
Anonymous
Unregistered

I'd like to echo Brian C.

I've had many customers over the years with relatives "back home" that they send money to on a regular basis, and use a debit card to do so.

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#2270446 - 05/14/22 12:49 PM Re: International Debit Card Activity ComplyGuy
rlcarey Offline
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Posts: 78,933
Galveston, TX
Check you debit card issuing agreement also, it used to be unless you were licensed to issue international debit cards, you are violating your agreement if you are providing debit cards to foreign nationals.
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