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New FinCEN Advisory Focuses on Essential Links between Corrupt Networks and Human Rights Abuses

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New FinCEN Advisory Focuses on Essential Links between Corrupt Networks and Human Rights Abuses

Posted by Enough Team on June 12, 2018

Washington D.C. –  Today, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued a new Advisory, Advisory on Human Rights Abuses Enabled by Corrupt Senior Foreign Political Figures and their Financial Facilitators, which focuses financial institutions on the urgent need to investigate and target the actions of corrupt Senior Politically Exposed Persons and their networks of facilitators and enablers around the world. The Advisory makes the critical connection of the corruption of these networks to grave human rights abuses, including in sub-Saharan Africa.

The Advisory presents typologies for how these corrupt networks move money, including through real estate transactions, identifies critical red flags for financial institutions to use in their investigations, and highlights specific examples, including from three countries in which The Sentry has active investigations: South Sudan, the Democratic Republic of Congo, and the Central African Republic.

John Prendergast, Co-Founder of The Sentry, said: “This action by FinCEN continues the critically important steps taken by the Treasury Department in recent months to address the connections between atrocities and corruption, including in the deadliest region of the world, East and Central Africa. Following up on the Global Magnitsky sanctions designations from December 2017, this Advisory shows that financial institutions can and must take action to stop enabling these corrupt and criminal networks from committing widespread abuses. This Advisory marks another important step in the strengthening of the U.S. government’s approach to countering corruption and human rights crimes.”

Joshua White, Director of Policy and Analysis at The Sentry, said: “FinCEN’s new advisory clearly underscores to the U.S. and global financial community the risks of doing business with those responsible for corruption and human rights abuses. Senior foreign political figures and their networks involved in countries where mass atrocities and armed violence are taking place, particularly in places like the Democratic Republic of Congo and South Sudan, represent a heightened risk that banks should carefully investigate. The red flags also ensure that banks can consider business in these regions in a targeted and nuanced way that avoids wholesale de-risking.”

For media inquiries or interview requests, please contact: Greg Hittelman, +1 310-717-0606,


The Sentry is composed of best-in-class financial forensic investigators, policy analysts, and regional experts who follow the dirty money and build investigative cases focusing on the corrupt transnational networks most responsible for Africa’s deadliest conflicts. By creating a significant financial cost to these kleptocrats through network sanctions, anti-money laundering measures, prosecutions, and other tools, The Sentry aims to disrupt the profit incentives for mass atrocities and oppression, and creates new leverage in support of peace efforts and African frontline human rights defenders. The Sentry’s partner, the Enough Project, undertakes high-level advocacy with policy-makers around the world as well as wide-reaching education campaigns by mobilizing students, faith-based groups, celebrities, and others. Co-founded by George Clooney and John Prendergast, The Sentry is an initiative of Not On Our Watch (NOOW) and the Enough Project. The Sentry currently focuses its work in South Sudan, Sudan, the Democratic Republic of Congo, Somalia, and the Central African Republic.

In less than two years, The Sentry has created hard-hitting reports and converted extensive research into a large volume of dossiers on individuals and entities connected to grand corruption, violence, or serious human rights abuses. The investigative team has turned those dossiers over to government regulatory and law enforcement agencies in the U.S. and around the world, as well as to compliance officers at the world’s largest banks.

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