Guidance to Financial Institutions on Filing Suspicious Activity Reports regarding the Proceeds of Foreign Corruption

Guidance
FIN-2008-G005
Issued: April 17, 2008
Subject: Guidance to Financial Institutions on Filing Suspicious Activity Reports regarding the Proceeds of Foreign Corruption The Financial Crimes Enforcement Network is issuing this guidance to financial institutions so that they may better assist law enforcement when filing Suspicious Activity Reports regarding financial transactions that may involve senior foreign political figures, acting individually or through government agencies and associated front companies, seeking to move the proceeds of foreign corruption to or through the U.S. financial system. The term “senior foreign political figure” includes: a current or former senior official of a foreign government or of a major foreign political party; a current or former senior executive of a foreign government-owned commercial enterprise; a corporation, business, or other entity that has been formed by, or for the benefit of, any such individual; the immediate family members of any such individual; and the widely and publicly, or actually, known close associates of any such individual.1 The term “proceeds of foreign corruption” means any asset or property that is acquired by, through, or on behalf of such corrupt public figures through misappropriation, theft, or embezzlement of public funds, the unlawful conversion of property of a foreign government, or through acts of bribery or extortion, and includes any property into which any such assets have been transformed or converted.2 In order to assist law enforcement in its efforts to target foreign corruption and related money laundering and, ultimately, deny the perpetrators access to the fruits of such corruption – and, in particular, to ensure that transactions relating to foreign corruption are identified by law enforcement as early as possible – we request that financial institutions include the term “foreign corruption” in the narrative portions of all Suspicious Activity Reports filed in connection with such activity.