Clifford Chance

FinCEN Warns U.S. Financial Institutions to be Alert to Venezuelan Public Corruption and Money Laundering

26 September 2017

On September 20, 2017, the Treasury Department's Financial Crimes Enforcement Network issued an advisory to U.S. financial institutions to be especially alert to suspicious activities involving Venezuelan public officials, employees of state-owned enterprises, and their families, which may involve the proceeds of public corruption. This expansive advisory includes a list of payment structures and transaction types that are examples of financial "red flags" of possible vehicles to illicitly embezzle funds to receive bribes. While the advisory is careful to admonish financial institutions not to indiscriminately de-risk, FinCEN clearly is putting the financial services industry on notice regarding their direct and indirect business with a wide swath of Venezuela-related business.

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