Regulatory Alerts2011-08-10 | FinCEN Advisory – FIN-2011-A013Added
Guidance to Financial Institutions on the Commercial Bank of Syria (FinCEN Advisory – FIN-2011-A013)
The Financial Crimes Enforcement Network reminds U.S. financial institutions of the continuing obligation to exercise due diligence regarding correspondent accounts to guard against the indirect use of those accounts by the Commercial Bank of Syria. The advisory warns that the Commercial Bank of Syria continues to maintain U.S. dollar-denominated accounts in Europe, the Middle East, and Asia, and may attempt to circumvent prohibitions through nested account activity. Financial institutions are advised to monitor for suspicious indicators such as transactions involving jurisdictions where the foreign financial institution has no known business or volumes exceeding expected activity. Additionally, U.S. financial institutions are reminded of their requirement under the Bank Secrecy Act to report suspicious transactions conducted or attempted by, at, or through the institution.