International Financial Law Prof Blog

Editor: William Byrnes
Texas A&M University
School of Law

Thursday, June 21, 2018

FinCEN Advisory on Human Rights Abuses Enabled by Corrupt Senior Foreign Political Figures and their Financial Facilitators

FinCEN Advisory On Human Rights Abuses 

High-level political corruption undermines democratic institutions and public trust, damages economic growth, and fosters a climate where financial crime and other forms of lawlessness can thrive. Corrupt senior foreign political figures, their subordinates and facilitators, through their corrupt actions, often contribute directly or indirectly to human rights abuses, which have a devastating impact on individual citizens and societies, undermining markets and economic development and creating instability in a region. The use of financial facilitators is one way that corrupt senior foreign political figures access the U.S. and international financial system to move or hide illicit proceeds, evade U.S. and global sanctions, or otherwise engage in illegal activity, including related human rights abuses.

Treasury employs its unique tools, consistent with applicable authorities, to impose financial consequences on those who pillage the wealth and  resources of their people, generate ill-gotten profits from corruption, cronyism, and other criminal activity, and engage in human rights abuses. These tools include the ability to sanction corrupt actors and human rights abusers around the world under an Executive Order implementing the Global Magnitsky Act of 2016,[1] taking enforcement action against financial facilitators of corrupt senior foreign political figures, as well as issuing advisories to financial institutions to help them identify, mitigate, and report on these risks.

[1] See Executive Order 13818, “Blocking the Property of Persons Involved in Serious Human Rights Abuse and Corruption,” December 20, 2017; see also United States Sanctions Human Rights Abusers and Corrupt Actors Across the Globe December 21, 2017.

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