The thirteen prominent Venezuelan nationals, added yesterday, by OFAC, to their SDN list, should be a wake-up call for you to examine, in detail, your customer lists. You are looking to reduce your level of risk of banking, directly or indirectly, the sanctioned individuals, their assets, or their funds transfers, in the period immediately prior to the imposition of sanctions, or the immediate aftermath.
Please secure the answers to these questions:
(1) Are any close relatives of those named clients of your bank ? Check last names; you are searching for relatives on both the sanctioned individuals' father's, as well as mothers' sides.
(2) Have any of the those clients made substantial transfers lately ? Where did the funds go ?
(3) Were any accounts opened recently ? Do any of those maintain substantial balances, or suspicious activity ?
(4) Do any of those bank customers live in the United States ? Are there any corporation accounts, in which they are signatories ?
You are advised to immediately check your bank's customer base for potential movement of funds, on behalf of newly-sanctioned Venezuelan PEPs.
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Chronicles of Monte Friesner - Financial Crime Analyst
Contributed by Kenneth Rijock - Financial Crime Consultant