FinCEN, OFAC, the UN, EU and UK Issue Advisories, Freeze Orders, Other Measures Related to Libya, Egypt and Tunisia

As a result of the recent unrest in Libya, Egypt and Tunisia, the U.S. Financial Crimes Enforcement Network ("FinCEN") has issued a series of advisories to remind financial institutions of their obligations under the USA PATRIOT Act to apply enhanced scrutiny for private bank accounts held by or on behalf of senior foreign political figures and to monitor transactions and file Suspicious Activity Reports involving transfers that may represent misappropriated or diverted state assets, proceeds of bribery or other illegal payments, or other public corruption proceeds. The FinCEN advisories draw particular attention to the fact that the recent instability in the area creates a heightened risk that senior foreign political figures (also known as politically exposed persons) in the Libyan, Egyptian and Tunisian governments may attempt to move misappropriated government funds out of their respective countries.