On August 21, 2019, the Financial Crimes Enforcement Network (FinCEN) issued an 18-page advisory to financial institutions to assist them in detecting and reporting opioid activity including fentanyl. FIN-2019-A006 lays out the various ways fentanyl and other opioids purchases are funded and how financial institutions get involved. Transactions can often involve money services businesses and bank transfers set up in such a way to evade Bank Secrecy Act (BSA) reporting requirements. The advisory goes into detail on the schemes to evade BSA detection and provides case studies. The advisory also provides red flag indicators of fentanyl-related activity, as well as the information to consider including in a Suspicious Activity Report and narrative.



John Zasada, JD, CAMS – Compliance Consulting Director, Financial Institutions Group. John can be reached at zasada@doeren.com.