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Senior foreign public officials are often private banking clients. In January 2001, “Guidance on Enhanced Scrutiny for Transactions that May Involve the Proceeds of Foreign Official Corruption” was issued by the Department of Treasury, the Office of the Comptroller of the Currency, the Office of Thrift Supervision, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the Department of State. The guidance contains suggested procedures for account opening and monitoring for persons known to be senior foreign political figures, their immediate family members and their close associates. It also contains a list of questionable or suspicious activities that may warrant enhanced scrutiny of transactions involving such persons. In addition, the USA PATRIOT Act requires enhanced due diligence and scrutiny for private banking accounts requested or maintained by senior foreign political figures, their immediate family members, and their close associates. U.S. financial institutions should apply these principles and requirements to private banking activities and accounts.

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