Regulatory Alerts2002-04-01 | FinCEN Advisory - Issue 32Added
Transactions Involving the Federal Republic of Nigeria (FinCEN Advisory - Issue 32)
The Financial Crimes Enforcement Network advises U.S. banks and financial institutions to apply enhanced scrutiny to transactions originating in, routed through, or involving entities in Nigeria due to serious deficiencies in the country's counter-money laundering systems. Institutions subject to suspicious transaction reporting rules must examine facts to determine if reporting is required, with particular attention to large sums, unestablished enterprises, and routing through third jurisdictions unrelated to commercial necessity. The Treasury Department confirms that reports filed regarding these transactions qualify for safe harbor protections against disclosure and liability under 31 U.S.C. 5318(g)(2) and (g)(3).
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