On 12th June, FinCEN published a new Advisory to US financial institutions to highlight the connection between corrupt senior foreign political figures and their enabling of human rights abuses. It says that the use of financial facilitators is one way that corrupt senior foreign political figures access the US and international financial systems to move or hide illicit proceeds and evade US and global sanctions. These corrupt senior foreign political figures and facilitators often contribute directly or indirectly to human rights abuses, which have a devastating impact on individual citizens, societies, and economic development. Facilitators may access the financial system to obscure and launder the illicit proceeds of high-level political corruption by using shell companies, misappropriating state assets, and exploiting the real estate sector. Consistent with existing regulatory obligations, financial institutions should take reasonable, risk-based steps to identify and limit exposure they may have to funds and other assets associated with individuals and entities providing financial facilitation for corrupt senior foreign political figures. The advisory also reminds financial institutions of their obligations regarding the filing of SAR related to facilitators of corrupt senior foreign political officials.
https://www.fincen.gov/resources/advisories/fincen-advisory-fin-2018-a003
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