On Tuesday, May 22, 2012, the U.S. Department of the Treasury (“Treasury”) designated JSC CredexBank (“Credex”), a financial institution based in Belarus, as a financial institution of primary money laundering concern pursuant to Section 311 of the USA PATRIOT Act (the “Designation”).

In the Designation, Treasury cited several reasons for classifying Credex as an institution of “primary moneylaundering concern,” including, but not limited to, Credex’s allegedhigh volume of transactions indicative of money laundering on behalf ofshell corporations and a history of ownership by shell corporations whose own lack of transparency contributes to considerable uncertainty surrounding Credex’s true beneficial ownership.

Also on Tuesday, May 22, 2012, Treasury’s Financial Crimes Enforcement Network filed a Notice of Proposed Rule Making (the “Notice”) in which it proposes requirements with respect to recordkeeping and reporting of certain financial transactions involving Credex, including attempted transactions, and proposes to prohibit U.S. financial institutions from opening or maintaining correspondent or payable-through accounts for Credex.

These measures are subject to a 60-day comment period, beginning the day the Notice is published in the Federal Register. TheDesignation is effective immediately.

As a result of theDesignation and the Notice, financial institutions may need to evaluateand update their existing compliance and risk management programs.

Read a complete copy of the Designation.

This publication is for general information only. It is not legal advice, and legal counsel should be contacted before any action is taken that might be influenced by this publication.

Established in 1925, Gunster is one of Florida’s oldest and largest full-service law firms. The firm’s clients include international, national and local businesses, institutions, local governments and prominent individuals. Gunster maintains its presence in Florida with offices in Fort Lauderdale, Jacksonville, Miami, Palm Beach, Stuart, Tallahassee, Tampa, Vero Beach and West Palm Beach. Gunster is home to more than 165 attorneys and 200 committed support staff, providing counsel to clients through 18 practice groups including banking & financial services; business litigation; construction; corporate; environmental & land use; government affairs; health care; immigration; international; labor & employment; leisure & resorts; private wealth services; probate, trust & guardianship litigation; professional malpractice; real estate; securities and corporate governance; tax; and technology & entrepreneurial companies. Gunster is ranked among the National Law Journal’s list of the 250 largest law firms.

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