On Friday, the Canadian FIU issued guidance on the Ukrainian regulations (FACFOU) promulgated recently under the Freezing Assets of Corrupt Foreign Officials Act (FACFOA):
Freezing and Disclosure Obligations Under FACFOA
All individuals and entities in Canada, and all Canadians outside of Canada, should be aware of the prohibition to conduct the following activities with corrupt foreign officials from Ukraine
- to deal, directly or indirectly, in any property, wherever situated, of a listed politically exposed foreign person;
- to enter into or facilitate, directly or indirectly, any financial transaction related to a dealing referred to in the previous point;
- to provide financial services or other related services in respect of any property of a listed politically exposed foreign person.
In addition, all individuals and entities in Canada, as well as every Canadian outside Canada, must advise the Commissioner of the Royal Canadian Mounted Police (RCMP) if they have property of any of these corrupt foreign officials in their possession or under their control; and information about a transaction or proposed transaction in respect of such property 2
In accordance with these regulations, a corrupt foreign official is one that is named in the Freezing Assets of Corrupt Foreign Officials (Ukraine) Regulations listed under Schedule 1. The Regulations are available at:http://www.international.gc.ca/sanctions/ukraine_developments-developpements_ukraine.aspx?lang=eng
A lot more succinct than the FinCEN one, to be sure.