Regulatory Alerts2017-09-20 | FinCEN Advisory FIN-2017-A006Added
Advisory to Financial Institutions on Widespread Political Corruption in Venezuela
FinCEN alerts financial institutions to widespread public corruption in Venezuela, detailing methods senior political figures and their associates may use to move and hide illicit proceeds. The advisory provides financial red flags to help institutions identify and report suspicious activity, such as abuse of government contracts, wire transfers from shell corporations, and real estate purchases in South Florida and Houston, Texas. It reminds U.S. financial institutions of their existing obligations, including enhanced due diligence for private banking accounts of senior foreign political figures under Section 312 of the USA PATRIOT Act, and general due diligence for correspondent accounts and AML programs. When filing a Suspicious Activity Report (SAR) related to this issue, institutions must select SAR field 35(l) and include "Venezuelan Corruption" in the narrative and SAR field 35(z).