FinCEN Issues Advisory on Kleptocracy and Foreign Public Corruption

The Financial Crimes Enforcement Network (FinCEN) today issued an advisory on kleptocracy and foreign public corruption, urging financial institutions to focus their efforts on detecting the proceeds of foreign public corruption—a priority for the U.S. Government as it continues to implement the U.S. Strategy on Countering Corruption. The advisory provides typologies and potential indicators of kleptocracy and other forms of foreign public corruption, namely bribery, embezzlement, extortion, and the misappropriation of public assets.

Kleptocrats and other corrupt public officials steal the public’s wealth for personal gain and use their positions of power and access to state-owned resources for their personal benefit. Like other criminal actors, corrupt public officials launder the proceeds of their corruption through a variety of means, including funneling money through shell companies or by purchasing various high-end assets, such as real estate, yachts, private jets and high value art.

“Foreign public corruption erodes public trust and disproportionately harms the most vulnerable in societies. Russia’s further invasion of Ukraine is a yet another example of how a kleptocracy like Russia—a country whose government has been characterized for years by corruption, money laundering, malign influence, sanctions evasions and armed interventions abroad—harms not only its own citizens, but those living beyond its borders,” said FinCEN Acting Director Himamauli Das. “Financial institutions play a crucial role in identifying corrupt activity and associated money laundering on the part of foreign public officials and should remain vigilant and promptly report suspicious financial activity.”

The advisory highlights financial red flag indicators to assist financial institutions in preventing, detecting, and reporting suspicious transactions associated with kleptocracy and foreign public corruption. For purposes of suspicious activity reporting, financial institutions should consider the relevant facts and circumstances of each transaction, in keeping with their risk-based approach to compliance.

Additionally, the U.S. Department of the Treasury last month launched the Kleptocracy Asset Recovery Rewards Program, which offers rewards payments for information leading to seizure, restraint, or forfeiture of assets linked to foreign government corruption, including the Government of the Russian Federation.  More information on eligibility for rewards payments and on submission of relevant information to the U.S. government can be found here. Those individuals with information are encouraged to contact or call +1 202-622-2050.

Financial Institution

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  • Depository Institutions
  • Insurance Industry
  • Money Services Businesses
  • Mortgage Co/Broker
  • Precious Metals/Jewelry Industry
  • Securities and Futures

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