The Office of Foreign Assets Control (OFAC) designated the mother-in-law of a Sinaloa Cartel leader recently; she is 85 years old. Sanctioned individuals often transfer ownership of their assets to extended family members, with special attention paid to those with different last names. Grown female children, whose names have been changed by marriage, are also typically used.
Remember, when banking any individual whose occupation and background do not match the level of assets he or she wishes to place on deposit, always consider that the person is fronting for a sanctioned party, who may be a distant relative, business associate, or partner of a relative. Always initiate enhanced due diligence, and require Source of funds proof, when you encounter a new client whose assets and wealth appear to be inconsistent with their personal and occupational history.