Ref. the subject matrix appearing in our favorite manual. If you are located in a state that was named a HIFCA but you live in an area that is not a drug kingdom....can we still say low or do we automatically have to say moderate?

One of the lists we have is the one that lists almost every country as potentially high for money laundering...is this the one we are to use or the OFAC lists that have a number but far less than the Dept. of State's list...? We do some wires in a few of the surprisingly risky countries and I was wondering how we should rate that, low or moderate 9And I mean a very few wires!). Thanks!

HIFCA adjacency - when in doubt as to whether low is accurate, go moderate. One could argue that even the lower-risk areas are easily accessible from the higher-risk areas by air, sea, train, or highway. Describe what you know about your area's role in drug trafficking, mentioning news reports or online sources, if you are going to try to defend "low."

The U.S. is among the riskiest countries, on this list: http://www.state.gov/p/inl/rls/nrcrpt/2008/vol2/html/100804.htm, which kind of negates the concept of wires from the U.S. to low-risk countries being low-risk, since the U.S. itself is high-risk. I usually see wires as described as high-risk by U.S. regulatory guidance, no matter what mitigants are in place.

If you do very few wires to non-U.S. countries, and have proper OFAC and other controls in place, it might allow rating as moderate (as opposed to high), but you might want to quantify it (i.e., using May 2008 as a representative example, we processed 300 wires, 298 of which were domestic, and 2 of which were to countries located in western Europe).