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OCC Bulletin 2006-23 | May 10, 2006

Bank Secrecy Act/Anti-Money Laundering: FinCEN Guidance to Financial Institutions on Providing Financial Services to Belarusian Senior Regime Elements


Chief Executive Officers and Compliance Officers of All National Banks, Federal Branches and Agencies, Department and Division Heads, and All Examining Personnel

This bulletin transmits the Financial Crimes Enforcement Network (FinCEN) advisory to U.S. financial institutions so that they may guard against a potential money laundering threat involving Belarusian government senior foreign political officials, their immediate family members, or persons widely and publicly known to be close associates seeking to move misappropriated Belarusian state assets as well as proceeds from illicit arms sales to or through the U.S. financial systems.

The U.S. Department of the Treasury has concerns that President Lukashenko, other senior Belarusian government officials, and senior Belarusian state business executives have been engaged in the abuse and theft of Belarusian public resources as well as arms sales to states of concern – including state sponsors of terrorism. This senior regime of the Belarusian government, acting individually or through government agencies and associated front companies may now be seeking to move the illicitly acquired financial assets abroad in advance of any international financial sanctions that could be imposed on Belarus.

The advisory provides guidance that is consistent with the Department of the Treasury's effort to ensure that U.S. financial institutions are not used as a conduit for laundering the proceeds of financial and other crimes, including corruption. National banks with questions about the advisory may contact the FinCEN's regulatory helpline at 1-800-949-2732.

Ann F. Jaedicke
Deputy Comptroller for Compliance Policy

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