Use of Alternative/Remittance Services

The FIU in Country 1 received three separate Suspicious Activity Reports. The reports identified three individuals- u, v and w- in Country 1 as frequent senders of funds to the same recipients- x, y and z- in Country 2.

Country 2 is known as a high risk jurisdiction for the illegal drug trade.

  • Receiver x was the target of the Drug Squad in Country 2; and
  • Receiver y was facing illegal drug charges in Country 3 and was previously convicted for illegal drugs and firearms in Country 2.

Intelligence was disclosed by the FIU to law enforcement authorities in Country 1.


  • Use of nominee, family members, third party
  • Sending to high risk jurisdiction
  • Use of non-domestic banks/businesses, including trust company service providers Structuring (Smurfing)