OCC Bulletin 2001-9| February 20, 2001

Bank Secrecy Act/Anti-Money-Laundering: Guidance on Foreign Official Corruption


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

The guidance attached to this bulletin continues to apply to federal savings associations.

On January 16, 2001, the Department of  the Treasury, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation, the Office of Thrift Supervision, the Board of Governors of the Federal Reserve System, and the Department of State issued the attached guidance to help U.S. financial institutions avoid transactions that may involve the proceeds of foreign official corruption.

The guidance encourages U.S. financial institutions to apply enhanced scrutiny to their private banking and similar high dollar-value accounts and transactions where such accounts or  transactions  may involve the proceeds of corruption by senior foreign political figures, their immediate family or close associates.  The guidance provides a set of suggested account establishment and maintenance procedures designed to help institutions obtain more appropriate information on accounts held by such persons, as well as a list of potentially suspicious transactions that may warrant enhanced scrutiny.

This guidance is not a rule or regulation and should not be interpreted as such.  It is advice that financial institutions are encouraged to employ in conjunction with policies, practices, and procedures that are in place to enable financial institutions to comply with applicable laws and regulations and to minimize reputational risks.  The federal financial institutions supervisory agencies will continue to monitor whether financial institutions have appropriate controls to identify and deter money laundering, but will not examine, review or audit financial institutions solely for compliance with this guidance. 

Questions may be directed to your OCC supervisory office or the Community and Consumer Policy Division at (202) 649-5740.

Ralph E. Sharpe
Deputy Comptroller
Community and Consumer Policy

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