Thursday, February 2, 2017

Anti-Money Laundering Obligations Associated With Latin America Customers Who Enter Regularization Programs?

Jones Day posted Tax Regularizations in Latin America: What's a Financial Institution to Do? which discusses that the increasing number of tax regularization programs in Latin America—most recently in Argentina, Brazil, Colombia, and Peru—is of keen interest to the cross-border wealth management industry.
These programs are the latest Latin models of the global transparency trend, and all four countries have announced their intention to participate in the OECD Automatic Exchange of Information program ("AEI") as soon as practicable. As a prelude to tax information exchange, all of these countries are offering their taxpayers the opportunity to regularize their assets before more punitive methods of enforcement occur in the post-AEI world.

The attractiveness of the regularizations has long sparked debate, and now U.S. financial institutions are wrestling with a related stark question: What, if any, anti-money laundering reporting obligations arise when a financial institution learns that a customer participates in a regularization?
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