Regulatory Alerts2008-04-17
Added
Guidance to Financial Institutions on Filing Suspicious Activity Reports regarding the Proceeds of Foreign Corruption
The Financial Crimes Enforcement Network requests that financial institutions include the term "foreign corruption" in the narrative portions of all Suspicious Activity Reports filed in connection with transactions involving senior foreign political figures or the proceeds of foreign corruption. This guidance reminds institutions of their obligations under 31 C.F.R. part 103 to implement risk-based policies and conduct customer due diligence, as well as their duties under section 312 of the USA PATRIOT Act to maintain enhanced scrutiny programs for private banking accounts held by senior foreign political figures. The document defines senior foreign political figures and proceeds of foreign corruption, requiring institutions to report transactions involving these entities if they know, suspect, or have reason to suspect involvement in illegal activity or money laundering.