Updated Advisory to Financial Institutions on Recent Events in Syria (FinCEN Advisory – FIN-2013-A002)

Advisory
FIN-2013-A002
Issued: April 15, 2013
Subject: Updated Advisory to Financial Institutions on Recent Events in Syria The Financial Crimes Enforcement Network (FinCEN) is issuing this Advisory to remind U.S. financial institutions to take reasonable, risk-based steps with respect to the potential movement of assets that may be related to the current unrest in Syria. Financial institutions should take into account ongoing events in Syria when assessing risks related to particular customers, accounts and transactions. On July 8, 2011, FinCEN issued an advisory regarding the possible flight of assets of certain individuals and entities believed to be associated with Syrian President Bashar al-Assad.1 Considering the prolonged unrest in Syria, FinCEN is providing additional advice to financial institutions on the risks and reporting requirements associated with these types of transactions. Guidance Covered financial institutions should review the regulations implementing Section 312 of the USA PATRIOT Act. These require U.S. financial institutions to perform due diligence or enhanced due diligence for correspondent accounts established, maintained, administered or managed in the United States for foreign financial institutions and for private banking accounts established, maintained, administered or managed in the United States for non-U.S. persons, that is reasonably designed to detect and report any known or suspected money laundering or other suspicious activity.2 In instances where senior foreign political figures3 maintain private banking accounts at a covered institution, those financial institutions are required to apply enhanced scrutiny to detect and report transactions that may involve the proceeds of foreign corruption,4 FIN-2011-A010. See 31 CFR § 1010.610 and 31 CFR § 1010.620. "Senior foreign political figure" means: (1) a current or former senior official of a foreign government or of a major foreign political party; (2) a senior executive of a foreign government-owned commercial enterprise; (3) a corporation, business, or other entity that has been formed by, or for the benefit of, any such individual; (4) the immediate family members of any such individual; and (5) 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). 31 CFR § 1010.620(c). This Advisory has been rescinded as of June 4, 2025.