FinCEN Red Flags for Auto Dealers

Customer pays for a vehicle entirely in cash, particularly when the amount exceeds $10,000 and no Form 8300 is filed, or the customer attempts to split the payment across multiple days to avoid reporting.

Customer makes a down payment in cash just below the $10,000 threshold and returns the next day to pay the remaining balance in a similar amount, suggesting intentional avoidance of Form 8300 filing.

Dealership receives payment for a vehicle from a wire originating from a cryptocurrency exchange, with the buyer claiming to have sold virtual currency to fund the purchase, but no documentation of the sale is provided.

Foreign national purchases a luxury vehicle with funds wired from a sanctioned jurisdiction, then requests immediate export to a non-sanctioned country where the vehicle will be resold to a sanctioned individual.

PEP purchases multiple luxury vehicles with funds wired from a government-owned bank account, and requests that the vehicles be shipped to a private compound or government facility in their home country.

Customer brings cash in small denominations ($20 and $50 bills) bundled with rubber bands, stored in a duffel bag or backpack, with no bank withdrawal slip or documented source of funds.

Vehicle purchase is funded by a wire from a third party with no documented relationship to the buyer, and the wire memo provides no explanation for why the third party is paying for the vehicle.

Foreign national wires funds from a high-risk jurisdiction to purchase a luxury vehicle for export, with no U.S. residency documentation and no explanation for why the vehicle is being purchased in the U.S.

Customer provides identification that appears tampered with or forged, or refuses to provide a government-issued photo ID for a cash transaction above the dealership’s internal threshold.

LLC or trust wires funds for a vehicle purchase but the beneficial owners are concealed, and the entity was recently formed with no business history or verifiable operations beyond this transaction.

Corporate customer purchasing a fleet of vehicles refuses to identify the beneficial owners, and the company is registered in a jurisdiction known for minimal disclosure requirements and shell company formation.

Customer purchases a vehicle with cash and immediately requests that the title be transferred to a third party with no familial or documented relationship, suggesting a straw buyer arrangement.