Regulatory Alerts2011-02-16 | FinCEN Advisory - FIN-2011-A002Added
Guidance to Financial Institutions on Recent Events in Egypt (FinCEN Advisory - FIN-2011-A002)
U.S. financial institutions must apply enhanced scrutiny to private banking accounts held by or on behalf of senior foreign political figures and monitor transactions for potential misappropriated or diverted state assets, bribery proceeds, or other public corruption proceeds. Institutions are required to file a Suspicious Activity Report if a transaction involving such figures involves illicit funds, lacks a lawful purpose, or indicates money laundering or terrorist financing. Covered institutions must also maintain written due diligence programs for private banking accounts held for non-U.S. persons to detect and report suspicious activity.