2018-09-11
The U.S. Department of the Treasury, via FinCEN, issues this advisory to alert U.S. financial institutions to the nexus between foreign corrupt political elites and human rights abuses, emphasizing the role of financial facilitators. It outlines typologies such as state resource embezzlement, shell companies, and real estate corruption, while detailing specific red flags for identifying illicit activities. The document reinforces obligations for risk-based due diligence, enhanced scrutiny for private banking accounts, and the filing of Suspicious Activity Reports (SARs) in compliance with the Global Magnitsky Act and FATF recommendations.