The Financial Crimes Enforcement Network (FinCEN) has published a Spanish version of its June advisory (FIN 2018-A003) alerting financial institutions of the connection between corrupt senior foreign political figures and their enabling of human rights abuses. The advisory reminds institutions of their Bank Secrecy Act (BSA)/anti-money laundering (AML) obligations regarding the filing of suspicious activity reports (SARs) related to facilitators of corrupt officials. That advisory, as reported here earlier, notes that U.S. financial institutions may expose themselves to risks by holding the accounts of these corrupt individuals directly or indirectly through correspondent banking relationships.
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