Regulatory Alerts2018-10-05
FinCEN Advisory FIN-2018-A005: Advisory to Financial Institutions on the Risk of Proceeds of Corruption in Nicaragua
The Financial Crimes Enforcement Network (FinCEN) issued this advisory to alert U.S. financial institutions to the risk that proceeds of political corruption from Nicaraguan officials linked to the Ortega regime may enter the U.S. financial system amid rising instability. The advisory mandates that institutions file Suspicious Activity Reports (SARs) when identifying potential misuse of public funds or corruption proceeds involving these foreign political figures, while emphasizing the need to maintain robust due diligence programs for private banking and correspondent accounts. It highlights recent OFAC sanctions under the Global Magnitsky Act against specific Nicaraguan officials for corruption and human rights abuses, urging institutions to utilize specific SAR fields to flag such activity for law enforcement analysis.