Bank Secrecy Act Guidance on Provision of Financial Services to Belarusian Senior Regime Elements Engaged in Illicit Activities

• 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. financial system.
• 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.

Distribution:
FDIC-Supervised Banks (Commercial and Savings)

Suggested Routing:
Chief Executive Officer
BSA Compliance Officer

Note:
FDIC Financial Institution Letters (FILs) may be accessed from the FDIC's Web site at www.fdic.gov/news/financial-institution-letters/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 Information Center, 3501 N. Fairfax Drive, Room E 1002, Arlington, VA 22226 (1-877-275-3342 or 703-562-2200).