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FinCEN Issues Advisory on Kleptocracy and Foreign Public Corruption
20 April 2022
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On April 14, 2022, the Financial Crimes Enforcement Network (“FinCEN”) released its “Advisory on Kleptocracy and Foreign Public Corruption” (the “Advisory”), urging covered financial institutions to prioritize identifying the proceeds of foreign public corruption.
The Advisory focuses on “wealth extraction” and the “laundering of illicit proceeds” as two key typologies of kleptocracy and foreign public corruption.
FinCEN identifies ten red flags implicating potential kleptocracy and foreign public corruption, which may trigger suspicious activity reporting requirements.
International Economic Sanctions & OFAC Compliance
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Satish M. Kini
Andrew M. Levine
Robert T. Dura
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