by Kara Brockmeyer, Andrew M. Levine, Satish Kini, Robert Dura, and Lily D. Vo
On April 14, 2022, the Financial Crimes Enforcement Network (“FinCEN”) released its “Advisory on Kleptocracy and Foreign Public Corruption” (the “Advisory”), directing covered financial institutions to focus their efforts on identifying the proceeds of foreign public corruption, which is a priority for the Biden administration.[1] The Advisory focuses on so-called “kleptocrats,” defined as individuals who use “their position and influence to enrich themselves and their networks of corrupt actors,” as well as other corrupt public officials who may launder the proceeds of their corruption through financial institutions.