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Events in Nicaragua could cause corrupt government officials, or Politically Exposed Persons (PEPs) associated with them, to choose to move some of their criminal proceeds out of the country, and into bank accounts in North America, or in the European Union.
The Financial Crimes Enforcement Network (FinCEN) has issued an Advisory, warning US financial institutions to be alert to the probability that affluent Nicaraguan nationals, professing to be business owners, independently wealthy individuals, purchasing agents for Nicaraguan trading companies, or other seemingly legitimate occupations, may seek to place dirty money at, or through, their bank, broker-dealer, or non-bank financial institution.
You are urged to:
(1) Read this Advisory.
(2) Show your frontline staff photographs of all senior Nicaraguan government officials.
(3) Run your facial recognition software program on ALL Nicaraguan nationals that seek to open new account relationships, or to make large deposits to, or wire transfers into, existing accounts. Corrupt Nicaraguan officials, or PEPs working for them, will have valid passports with clean aliases, and only facial recognition software will properly identify their true names.
(4) Use bank staff members of Nicaraguan extraction, if possible, for any major new clients from Latin America, as they will be able to spot Nicaraguan nationals posing as citizens of other nations, through their regional accents and use of Nicaragua slang.
(5) Decline their business, and document and report all such actions to your legal counsel, and consider the filing of a Suspicious Activity Report (SAR) .
Chronicles of Monte Friesner - Financial Crime Analyst 
Contributed by Kenneth Rijock - Financial Crime Consultant
