With all the hype lately about the legalization of marijuana and hemp we need to make sure we don’t lose focus of areas of illegal drug activity, High Intensity Drug Trafficking Areas or HIDTAs. HIDTAs began being tracked back in 1990 with the passing of the Anti-Drug Abuse Act of 1988. The HIDTA program helps coordinate drug control efforts through out our country at the local, state and federal level. The United States Drug Enforcement Administration runs the HIDTA program, which operates as a grant program and maintains an annual budget of around $250 million (2016).
All 50 states are now participating in the HIDTA program, as of May 2018; and have identified activity on the list. The list also includes Puerto Rico, the US Virgin Islands and the District of Columbia. In the continental United States, there is not a state that doesn’t have a county on this list. Sadly, this is a bit of a wake-up call to highlight the on-going drug problem in our country. Though some states may have minimal activity, many adjoin a neighboring state line where several counties are affected.
So how does this affect banking? You guessed it, money laundering. It is important to identify HIDTAs in your BSA program. This is especially important to ensure it is reflected in your BSA Risk Assessment. HIDTAs should be identified under the geographic risk section of your assessment. If you have any branches in a listed county, it would significantly increase your geographical risk rating. We recommend listing out, in the BSA/AML Risk Assessment, each HIDTA county where a branch is located.
Something else to consider is employee education. As I am sure everyone in your institution is well aware of your state and local standing on marijuana and hemp. But do you educate on HIDTAs in your state? HIDTA is a common acronym in the world of BSA. However, we often forget to educate our employees of the level of illegal drug activity happening in our own back yard. If you have branches in an identified county it is even more important to educate on the elevated risk for drug related money laundering in that particular county and the surrounding area.
If you haven’t investigated this before it can be a rather eye-opening experience. Guidance is also available in the FFIEC BSA/AML Examination Manual. In addition, the DEA publishes a HIDTA map of the qualifying counties. https://www.dea.gov/high-intensity-drug-trafficking-areas-hidta