On 4th October, FinCEN issued an Advisory (in Spanish and English) warning that financial institutions of the increasing risk that proceeds of political corruption from Nicaragua may enter or traverse the US financial system.  FinCEN says that it expects that senior foreign political figures connected to the regime of Nicaraguan President Daniel Ortega could react to the perceived threat of further unrest, potential sanctions, or other factors by moving assets out of their accounts in Nicaragua or elsewhere. These assets could be the proceeds of corruption.  The Advisory reminds one that to date OFAC has designated 4 senior officials — within the Nicaraguan government, the Sandinista National Liberation Front, and ALBA de Nicaragua (ALBANISA), the company that imports and sells Venezuelan petroleum products — under the Global Magnitsky authority, which enables Treasury to target corrupt officials, human rights abusers, and their facilitators around the world. In doing so, OFAC highlighted these officials’ roles in corrupt and violent acts, which include involvement in human rights abuses, illicitly amassing sizeable personal wealth, stealing large sums of money from municipal projects, and exploiting government funds for the personal use of Nicaraguan leaders.  The Advisory also said that FinCEN previously published an Advisory in June in which it identified typologies and red flags illustrating how corrupt senior foreign political figures and their facilitators access the US financial system to obscure and launder the proceeds of high-level political corruption. Financial institutions may reference today’s advisory together with the June 2018 advisory at –

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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