Regulatory Alerts2017-09-06 | FinCEN Advisory FIN-2017-A004Added
Advisory to Financial Institutions on Political Corruption Risks in South Sudan (FinCEN Advisory FIN-2017-A004)
U.S. financial institutions are reminded of their due diligence and suspicious activity report (SAR) filing obligations regarding senior foreign political figures who may attempt to use the U.S. financial system to move or hide proceeds of public corruption from South Sudan. The advisory highlights specific corrupt practices, including the use of shell companies and abuse of government contracting, and lists nine sanctioned South Sudanese persons and three companies subject to OFAC and UN asset freezes. Institutions must apply enhanced scrutiny to private banking accounts held by these figures and ensure correspondent account due diligence programs include risk-based controls to detect money laundering. When filing SARs related to these activities, institutions must select field 35(l) for suspected public or private corruption and reference the key term SOUTH SUDAN in the narrative and field 35(z).