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FinCEN's Most Lethal AML Weapon Against Foreign Banks

Arthur Middlemiss
January 13, 2020

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.

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. 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.

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