The Criminal Offenses
Definitions under Section 6313
Does your Financial Institution Know its Clients?
Financial Institutions need to figure out if senior foreign political figures (or their family members or close associates) and entities found to be of primary money-laundering concern are in their client roster.
Financial institutions should evaluate the effectiveness of their existing KYC and BSA/AML process and ensure the process is working to document these types of clients and monitor their activity.
To the extent that a Financial Institution does not have a sound process in place, it should immediately consult with a Corporate Governance Expert.
Who is your Corporate Governance Expert?