Regulatory Alerts2011-02-24 | FinCEN Advisory – FIN-2011-A004Added
Guidance to Financial Institutions on Recent Events in Libya (FinCEN Advisory – FIN-2011-A004)
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 state assets, bribery proceeds, or other public corruption funds. Institutions are required to file Suspicious Activity Reports if they know, suspect, or have reason to suspect that transactions involving these figures involve illicit funds, lack a lawful purpose, or indicate 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 related to foreign corruption.