FinCEN updates an advisory on corruption and money-laundering with regard to Venezuela

The United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has updated an advisory on Venezuela (FIN-2019-A002). In the document, which was published on 3 May 2019, FinCEN warns of “continuing widespread public corruption in Venezuela under the regime of Nicolas Maduro, which the U.S. Government considers illegimate” (page 1). According to the advisory and a related news release, illegal funds of the Venezuelan government derive, for instance, from misappropriated funds from the food supply system CLAP (Los Comités Locales de Abastecimiento y Producción) as well as from the use of a digital currency designed for the evasion of foreign sanctions. FinCEN specifies several red flags for financial transactions and reminds financial institutions of their responsibilities relating to due diligence according to the Bank Secrecy Act (BSA) and the filing of Suspicious Activity Reporting (SAR).