Guidance on Enhanced Scrutiny for Transactions That May Involve Proceeds of Foreign Official Corruption
February 6, 2001
Circular No. 11319

To All State Member Banks, Bank Holding Companies, Edge Corporations, and U.S. Branches and Agencies of Foreign Banks in the Second Federal Reserve District:

In a press release dated January 16, 2001, the Board of Governors of the Federal Reserve System announced the development of guidance (pdf - 28kb) designed to assist financial institutions in applying enhanced scrutiny to transactions by senior foreign political figures and their immediate families and close associates. It also contains a list of questionable or suspicious activities.

Financial institutions are encouraged to use the guidance, which was enclosed with a supervisory letter to Federal Reserve Banks and to domestic and foreign banking organizations supervised by the Federal Reserve, as they seek to deter money laundering and minimize legal risks and potential reputational damage.

Any questions on the guidance should be directed, at this Bank, to Nicholas Farco, Examining Officer.