On April 14, 2022, The Financial Crimes Enforcement Network released an Advisory, available here, urging financial institutions to prioritize detecting proceeds of foreign corruption and reporting related suspicious financial activity. The Advisory provides typologies highlighting examples of bribery, extortion, misappropriation and embezzlement by corrupt officials and potential "red flag" indicators of foreign public corruption that financial institutions should focus on to strengthen their anti-corruption efforts within their existing risk-based anti-money laundering compliance programs. It also reminds financial institutions of their reporting requirements under the Bank Secrecy Act and USA PATRIOT Act.
Broadly, this Advisory is the latest part of a larger push by the Biden Administration to counter corruption, pursuant to its "United States Strategy on Countering Corruption," available here. We have previously written about the Administration's anti-corruption strategy here. This Advisory is also in line with recent sanctions efforts by the Administration following Russia's invasion of Ukraine in February 2022.