Regulatory Alerts2011-07-08 | FinCEN Advisory – FIN-2011-A010Added
Guidance to Financial Institutions on Recent Events in Syria (FinCEN Advisory – FIN-2011-A010)
U.S. financial institutions are required to take reasonable risk-based steps and apply enhanced scrutiny to private banking accounts held by or on behalf of senior foreign political figures to detect transactions involving misappropriated state assets, bribery, or other public corruption proceeds. The advisory specifically highlights the need to monitor activities linked to Rami Makhluf and his designated entities, noting that he is taking steps to protect his wealth outside of Syria. Institutions must file Suspicious Activity Reports if they know, suspect, or have reason to suspect that transactions involve funds derived from illicit activity or appear to have no lawful purpose.