Guidance to Financial Institutions on Recent Events in Syria (FinCEN Advisory – FIN-2011-A010)

Department of the Treasury
Financial Crimes Enforcement Network
Advisory
FIN-2011-A010
Issued: July 8, 2011
Subject: Guidance to Financial Institutions on Recent Events in Syria The Financial Crimes Enforcement Network (FinCEN) is issuing this Advisory to U.S. financial institutions to take reasonable risk-based steps with respect to the potential increased movement of assets that may be related to the current unrest in Syria. 1 During this period of uncertainty, FinCEN is issuing this Advisory to remind U.S. financial institutions of their requirement to apply enhanced scrutiny for private banking accounts held by or on behalf of senior foreign political figures2 and to monitor transactions that could potentially represent misappropriated or diverted state assets, proceeds of bribery or other illegal payments, or other public corruption proceeds. Financial institutions should be aware of the possible impact the events in Syria may have on patterns of financial activity when assessing risks related to particular customers and transactions. For example, as a result of the unrest in Syria, information available to the U.S. Government indicates Rami Makhluf, a cousin to Syrian President Bashar Assad and prominent Syrian businessman, is taking steps to protect his money, properties and companies. Rami Makhluf was designated by the Department of the Treasury’s Office of Foreign Assets Control (OFAC) on February 21, 2008 for improperly benefiting from and aiding the public corruption of Syrian regime officials.3 On May 18, 2011, OFAC also designated three companies and one individual for their links to Makhluf: Cham Holding and its Chairman Nabil Rafik al Kuzbari, Bena Properties, and Al Mashreq Investment Fund.4 1 For information from the United States Department of State regarding developments in Syria, please see Further, on July 10, 2008, OFAC identified Syriatel and Ramak, two http://www.travel.state.gov/travel/cis_pa_tw/cis/cis_1035.html. 2 "Senior foreign political figure" means a current or former senior official of a foreign government or of a major foreign political party; a 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 a person who is widely and publicly known (or is actually known by the relevant covered financial institution) to be a close associate of such individual. For the purposes of this definition, "senior official or executive" means an individual with substantial authority over policy, operations, or the use of government-owned resources and "immediate family member" means spouses, parents, siblings, children and a spouse's parents and siblings. See 31 CFR 1010.620(c) and 31 CFR 1010.605(p). 3 Office of Foreign Assets Control, “Changes to List of Specially Designated Nationals and Blocked Persons Since January 1, 2008.” (February 21, 2008). http://www.treasury.gov/resource￾center/sanctions/SDN-List/Documents/sdnew08.pdf, and see generally, HP-834,
“Rami Makhluf Designated for Benefiting from Syrian Corruption” (February 21, 2008). http://www.treasury.gov/press￾center/press-releases/Pages/hp834.aspx. 4 Office of Foreign Assets Control, “Changes to List of Specially Designated Nationals and Blocked Persons Since January 1, 2011.” (May 18, 2011). http://www.treasury.gov/ofac/downloads/t11sdnew.pdf, This Advisory has been rescinded as of June 4, 2025.