Merchant Account Underwriting Tools

FINCEN ADVISORY MAY 20, 2014

The Alert A004 can apply equally to merchant account applicants.

“Certain foreign individuals are abusing the Citizenship-
by-Investment program sponsored by the Federation of St. Kitts and Nevis (SKN) to obtain SKN passports for the purpose of engaging in illicit financial activity. Financial institutions can mitigate exposure to such risk through customer due diligence, including risk-based identity verification consistent with existing customer identification program requirements.”

http://www.fincen.gov/news_room/advisory/

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