In Nigeria, there were no new cases of WPV reported in 2017. The work of in- country partners (e.g., WHO, UNICEF), in coordination with GID’s support to the MOH, resulted in steady progress toward eradicating polio, with the number of cases at a record low of only eight WPV cases in 2017 as compared to the previously record of 20 in 2016. In Pakistan, GID is deeply invested in Pakistan’s NSTOP program, which recruited 65 officers to work in all aspects of polio eradication activities, including vaccination campaign microplanning and implementation, acute flaccid paralysis (AFP) surveillance, and case investigations. In Afghanistan, GID works closely with in-country contractors and the International Federation of Red Cross and Red Crescent Societies to improve case investigation and campaign monitoring to ensure every child is vaccinated. Substantial progress toward global polio eradication continues, with only 22 cases reported in 2017. See Paul, Weiss, FinCEN Imposes Anti-Money Laundering Reporting Requirements On “All Cash” Luxury Real Estate Purchases in Manhattan and Miami (February 2, 2016), available here.Supporting Global Polio Eradication EffortsĬDC’s Global Immunization Division (GID) continues to play a key role in reducing the number of WPV cases. Supplemental Information Regarding the Final Rule Imposing the Fifth Special Measure Against FBME Bank, Ltd., 81 Fed. See Paul, Weiss, Economic Sanctions and Anti-Money Laundering Developments: 2017 Year in Review (January 23, 2018), available here. FinCEN, New FinCEN Division Focuses on Identifying Primary Foreign Money Laundering Threats (August 28, 2019), available here. With the establishment of the GID, FinCEN will now have one dedicated division focused on exercising its Section 311 and GTO authorities to “maximum effect” to detect and deter potential threats, “including those that have a nexus to the proliferation of weapons of mass destruction, rogue state actors, transnational organized crime, international narcotics trafficking, and terrorism.” Financial institutions can expect FinCEN to make greater use of these special authorities going forward. In recent years, specific money laundering concerns have motivated FinCEN to issue GTOs in several areas, including armored cars crossing the U.S./Mexico border, transactions with garment and textile businesses in Los Angeles’ fashion district, and luxury real estate purchases in major metropolitan areas.
There are civil and criminal penalties for failing to comply with a GTO’s requirements. Geographic Targeting Orders (“GTOs”): FinCEN has the authority to issue GTOs that require all identified businesses within a geographic area to report on specified transactions.In 2016, FinCEN similarly designated FBME, a Tanzania-based bank that largely operates in Cyprus, due to FBME’s alleged AML and sanctions control deficiencies, its extensive customer base of shell companies, and its provision of financial services to transnational organized crime groups and Hezbollah, among others. For example, in 2017, FinCEN invoked Section 311 to designate China-based Bank of Dandong as an institution of primary money laundering concern based on its alleged processing of North Korean transactions, effectively cutting the institution off from the U.S. correspondent bank accounts used for clearing U.S. Section 311 of the USA PATRIOT Act: Under Section 311, if FinCEN finds that a foreign jurisdiction, financial institution, or class of transactions qualifies as a “primary money laundering concern,” it may initiate rulemaking that would impose one or more of five different “special measures.” FinCEN has used this authority to designate foreign banks in Europe, the Middle East and Asia that are found to have deficient anti-money laundering (“AML”) controls and to prohibit those banks from opening or maintaining U.S.Matthew Stiglitz, a former Principal Deputy Chief in the Department of Justice’s Criminal Division, will lead the GID.įinCEN’s GID expects to make particular use of two authorities: Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced the launch of a new Global Investigations Division (“GID”), which will be responsible for implementing “targeted investigation strategies” to combat illicit finance threats and related crimes, both domestically and internationally. Data Innovation, Privacy & Cybersecurity.Family Office & High-Net-Worth Individuals.
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