Please read all of the paragraphs preceding the one you quote. Others can find them beginning on page 36 (document not pdf) of
SAR Activity Review #10.
As your emphasized language indicates, they are talking about "third party receivers of funds." I acknowledge that they added another type of scam they do not want to hear about if there is no monetary loss. They explain that scam in detail, describing the fact situation as "slightly different" than the 419 scenario. They emphasize that it has features similar to 419 scams and give specific examples.
It is a slight expansion of their prior position, not a revelation. They leave no room for third party extrapolation. The expansion definitely does not include every situation where there might be an overpayment or a transfer of funds outside the U.S. and no amount of massage can expand it to include the scenarios posed in the post that started this thread.
You indicate:
Quote:
I've interpreted this to apply to any type of advance fee fraud, lottery scam or the like.
As you note, the interpretation is yours. Before you implement it or offer it to others, you should find confirming sources within both FinCEN and your regulatory agency.