Regulatory Alerts2013-04-15 | FinCEN Advisory – FIN-2013-A002Added
Updated Advisory to Financial Institutions on Recent Events in Syria (FinCEN Advisory – FIN-2013-A002)
U.S. financial institutions must take reasonable, risk-based steps to assess risks related to customers, accounts, and transactions involving potential asset movements linked to unrest in Syria. Covered institutions are required to perform due diligence or enhanced due diligence for correspondent and private banking accounts, applying enhanced scrutiny to transactions involving senior foreign political figures to detect proceeds of foreign corruption or misappropriated state assets. When filing Suspicious Activity Reports for such activity, institutions must check item 35(l) for suspected public or private corruption, include the term "Syria" in the narrative, and attach detailed transactional records using the new Excel-compatible CSV file option.