Alert July 12, 2011

FinCEN Issues Guidance on Actions that U.S. Financial Institutions Should Take as a Result of Recent Unrest in Syria

The Financial Crimes Enforcement Network (“FinCEN”) issued an advisory (the “Advisory“) urging U.S. financial institutions (“FIs”) “to take reasonable risk-based steps with respect to the potential increased movement of assets that may be related to the current unrest in Syria.”  The Advisory reminds FIs to apply enhanced scrutiny to their review of private banking accounts of foreign political figures, and to their monitoring of transactions for potentially misappropriated or diverted state assets, the proceeds of bribery or public corruption and for other illegal payments.