OCC 2006-23
OCC Bulletin

    Subject:  Bank Secrecy Act/Anti-Money Laundering
Description:  FinCEN Guidance to Financial Institutions
              on Providing Financial Services to 
              Belarusian Senior Regime Elements

       Date:  May 10, 2006

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

This bulletin transmits the Financial Crimes Enforcement
Network (FinCEN) advisory to U.S. financial institutions
so that they may guard against a potential money 
laundering threat involving Belarusian government senior
foreign political officials, their immediate family 
members, or persons widely and publicly known to be close
associates seeking to move misappropriated Belarusian 
state assets as well as proceeds from illicit arms sales
to or through the U.S. financial systems.

The U.S. Department of the Treasury has concerns that 
President Lukashenko, other senior Belarusian government
officials, and senior Belarusian state business 
executives have been engaged in the abuse and theft of 
Belarusian public resources as well as arms sales to 
states of concern - including state sponsors of terrorism
This senior regime of the Belarusian government, acting
individually or through government agencies and 
associated front companies may now be seeking to move the
illicitly acquired financial assets abroad in advance of
any international financial sanctions that could be 
imposed on Belarus.     

The advisory provides guidance that is consistent with the 
Department of the Treasury's effort to ensure that U.S. 
financial institutions are not used as a conduit for 
laundering the proceeds of financial and other crimes,
including corruption.  National banks with questions 
about the advisory may contact the FinCEN's regulatory 
helpline at 1-800-949-2732.  



_________________________
Ann F. Jaedicke
Deputy Comptroller for Compliance Policy


Attachments- FinCEN Advisory: Belarus
      [http://www.fincen.gov/advisory_belarus040706.html]