2011-01-20 | FinCEN Advisory – FIN-2011-A001Added · Updated
U.S. financial institutions are required to apply enhanced scrutiny to private banking accounts held by or on behalf of senior foreign political figures and to monitor transactions potentially involving misappropriated state assets, bribery proceeds, or other public corruption proceeds originating in or diverted from Tunisia. Institutions must file Suspicious Activity Reports if they know, suspect, or have reason to suspect that transactions relating to senior foreign political figures involve illicit funds, lack a lawful purpose, or indicate money laundering or terrorist financing. Covered institutions are also reminded of their obligation to maintain written due diligence programs for private banking accounts held for non-U.S. persons to detect and report known or suspected money laundering or other suspicious activity.
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Department of the Treasury
Financial Crimes Enforcement Network
Advisory
FIN-2011-A001
Issued: January 20, 2011
Subject: Guidance to Financial Institutions on Recent Events in Tunisia The Financial Crimes Enforcement Network (FinCEN) is issuing this Advisory to U.S. financial institutions to take reasonable steps to guard against the potential flow of illicit assets that may be related to the current political and social unrest in Tunisia and abrupt changes in the government in Tunisia.1 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 originating in or diverted from Tunisia. Financial institutions should be aware of the possible impact that political and social unrest in Tunisia may have on patterns of financial activity in the region when assessing risks related to particular customers and transactions. 3 Guidance If a financial institution knows, suspects, or has reason to suspect that a transaction relating to senior foreign political figures involves funds derived from illicit activity, if the transaction appears to have no business or lawful purpose, or if a customer has engaged in activities indicative of money laundering, terrorist financing, or any other violation of federal law or regulation, the financial institution must file a Suspicious
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Source: Financial Crimes Enforcement Network — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works