FinCEN's Most Lethal AML Weapon Against Foreign Banks

Law360 (January 13, 2020, 5:39 PM EST) -- In 2020 and beyond, foreign banks should expect the U.S. Department of the Treasury's Financial Crimes Enforcement Network, or FinCEN, to expand its use of so-called special measures.[1]

This is because, in its 2020 budget and performance report, FinCEN reported plans to increase by 30% its use of such measures authorized by Section 311 of the USA Patriot Act.[2] Under Section 311, there are multiple types of special measures, but we focus here on the most lethal of FinCEN's weapons: the ability to prohibit the opening or maintaining of correspondent accounts.[3]

In relevant part, Section 311 empowers FinCEN to "prohibit, or...

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