AL 2002-2
Advisory Letter
Subject: U.S. Department of Treasury FinCEN Advisories 
         11A and 21A
Date: February 27, 2002

TO:   Chief Executive Officers and Compliance Officers of
      National Banks and Federal Branches, Department and
      Division Heads, and Examining Personnel

This advisory letter revises the list of countries 
detailed in OCC Advisory Letter (AL) 2000-8, "U.S. 
Department of Treasury FinCEN Advisories 13 through 27," 
dated August 9, 2000 and AL 2001-7, "U.S. Department of 
Treasury FinCEN Advisories 13A, 14A, 19A, 23A," dated 
July 25, 2001.

In July 2000, the U.S. Department of the Treasury's 
Financial Crimes Enforcement Network (FinCEN) issued a 
series of advisories identifying 15 countries with 
serious deficiencies in their counter-money-laundering 
systems.   Recently, FinCEN issued the attached Advisory 
21A regarding the Republic of Nauru and continuing 
concerns about Nauru's counter-money-laundering systems. 
Advisory 21A supplements FinCEN Advisory 21 (Nauru), 
issued in July 2000. The advisory reminds banks, in 
addition to using enhanced scrutiny recommended in 
Advisory 21, to comply with the requirements of Section 
313 of the USA PATRIOT Act of 2001 with respect to 
correspondent accounts with foreign shell banks. FinCEN's
supplemental Advisory 21A is consistent with the recent 
decision of the Financial Action Task Force on Money 
Laundering (FATF) to impose countermeasures against 
Nauru.

In addition, due to the enactment of significant reforms 
to its counter-money-laundering systems and the concrete 
steps being taken to bring these reforms into effect, 
FinCEN has issued Advisory 11A, which supersedes and 
withdraws Advisory 11 (Antigua and Barbuda), issued in 
April 1999.

Following the issuance of advisories 11A and 21A, FinCEN 
advisories remain in effect for the following 
jurisdictions :

· The Cook Islands,
· Dominica,
· Israel,
· Lebanon,
· The Marshall Islands,
· Nauru,
· Niue,
· The Philippines,
· The Russian Federation,
· St. Kitts and Nevis,
· St. Vincent and The Grenadines, and
· The Seychelles.

The FinCEN advisories emphasize the need for enhanced 
scrutiny of certain transactions and banking relationships 
in these jurisdictions to ensure that appropriate measures 
are taken to minimize risk for money laundering.  Please 
refer to OCC AL 2000-8 for additional information on 
banking relationships in the subject jurisdictions.  Also, 
refer to the Bank Secrecy Act/Anti-money Laundering 
booklet in the Comptroller's Handbook and OCC AL 2000-3 
for guidance on controlling risk of money laundering.  
Copies of the booklet and the OCC advisory letters are 
available at [www.occ.treas.gov/handbook/bsa.pdf] and 
[www.occ.treas.gov/advlst00.htm].

If you have any questions, or need copies of the new 
FinCEN advisories, please contact your supervisory office 
or the Compliance Division at (202) 874-4428.




__________________

David G. Hammaker
Deputy Comptroller for Compliance



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