OCC 2001-9
OCC Bulletin
February 20, 2001
Subject: Bank Secrecy Act/Anti-Money-Laundering
Description: Guidance on Foreign Official Corruption

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) 874-4428. 


Ralph E. Sharpe
Deputy Comptroller
Community and Consumer Policy

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