- On April 10, 2006, FinCEN issued an advisory to financial institutions
regarding the provision of financial services to Belarusian senior
regime elements engaged in illicit activities.
- There is concern that Belarusian government senior regime elements
acting individually or through government agencies and associated front
companies may attempt to move misappropriated Belarusian state assets as
well as proceeds from illicit arms sales to or through the U.S.
- The Department of Treasury has concerns with President Lukashenko and
other senior members of the Belarusian government who have reportedly
been engaged in the abuse and theft of Belarusian public resources as
well as arms sales to states of concern. There may be attempts to move
illicitly acquired financial assets abroad in advance of the imposition
of international financial sanctions on Belarus.
- Financial institutions are reminded of the requirement to implement
appropriate risk-based policies, procedures, and processes, including
conducting customer due diligence on a risk-assessed basis to aid in the
identification of potentially suspicious transactions.
FDIC-Supervised Banks (Commercial and Savings)
Chief Executive Officer
BSA Compliance Officer
Bank Secrecy Act
FinCEN Advisory FIN-2006-G002 - PDF 45k (PDF Help)
Examiner Debra L. Novak at
SASFIL@FDIC.gov or (202) 898-3673
Financial Institution Letters (FILs) may be accessed from the FDIC's Web
site at www.fdic.gov/news/news/financial/2006/index.html.
To receive FILs electronically, please visit http://www.fdic.gov/about/subscriptions/fil.html.
Paper copies of FDIC FILs may be obtained through the FDIC's Public
3501 N. Fairfax Drive, Room E 1002, Arlington, VA 22226 (1-877-275-3342