One small way you can help victims of human rights abuses
This morning I watched the news while getting ready for work, checked my social media, and listened to the radio on the drive in – so I know I that am not alone in my concerns for the state of the world we are living in and raising children in. Some days I feel helpless, but I know that there are small things we can all do that make a big impact, which brings me to an advisory recently issued by the Financial Crimes Enforcement Network (FinCEN).
FIN-2018-A003: Advisory on Human Rights Abuses Enabled by Corrupt Senior Foreign Political Figures and their Financial Facilitators is an important reminder to financial institutions about their role in detecting and reporting suspicious activity related to politically exposed persons (PEPs). The advisory is recommended reading for CEOs, COOs, compliance, risk and legal departments, and is intended to highlight the connection between corrupt PEPs and their enabling of human rights abuses. In it, FinCEN describes a number of typologies used by PEPs to access the U.S. financial system to obscure and further their illicit activity. These may include the misappropriation of state assets, the use of shell companies, the exploitation of the real estate sector, or any combination of these methods.
The advisory provides several red flags that can assist financial institutions in identifying the methods used by corrupt PEPs to hide the proceeds of their activities, which contribute directly or indirectly to human rights abuses. In addition, it reminds financial institutions of their requirements under BSA to conduct due diligence and file suspicious activity reports (SARs) when warranted.
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