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FinCEN Issues Banking Advisory on Corrupt Transactions, Sanctions Evasion

The Financial Crimes Enforcement Network issued an advisory April 14 urging banks and other financial institutions to focus on catching illegal transactions related to kleptocracy and corruption. The advisory outlines various “typologies and potential indicators” of kleptocracy and other forms…

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of foreign corruption, including bribery, embezzlement, extortion and the “misappropriation of public assets.” The advisory said banks should specifically scrutinize Russia-related transactions for “sanctions evasion” attempts. It also outlines suspicious-activity report filing requirements for transactions that banks may suspect of violating sanctions.