Key insights include:
➡️ Identity Theft Risks: FinCEN highlights schemes involving stolen Social Security Numbers (SSNs) and other Personally Identifiable Information (PII) to gain unlawful employment, wages, benefits, financial services and credit;
➡️ Payroll Fraud Schemes: Complicit employers may use off-the-books payments, shell companies, unregistered Money Services Business’, check cashing and structured withdrawals to conceal unlawful employment; and
➡️ Red Flag Indicators: FinCEN sets out indicators involving SSN mismatches, recurring check deposits, structured cash withdrawals, peer-to-peer (P2P) payments, limited payroll activity and shell company characteristics.
✅ Firms should review customer due diligence (CDD), transaction monitoring (TM) and SAR escalation controls against the red flags highlighted in the advisory.