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September 26, 2018 Update: The Banking Transparency for Sanctioned Persons Act of 2018 was passed by the U.S. House of Representatives on September 26, 2018.

New House Bill Requires Treasury Department Reporting Financial Institutions’ Dealings with State Sponsors of Terrorism and Persons Sanctioned Under Magnitsky Laws

On September 7, 2018, Congresswoman Mia Love (R-UT) introduced in the House of Representatives H.R. 6751, the Banking Transparency for Sanctioned Persons Act of 2018 (the “Banking Transparency Bill” or “BTB”).[i] Referred initially to the House Committee on Financial Services, of which Congresswoman Love is a majority party member, the Banking Transparency Bill’s purpose is to, inter alia, “increase transparency with respect to financial services benefitting state sponsors of terrorism, human rights abusers, and corrupt officials.” On September 13, 2018, the voting members of the House Committee on Financial Services unanimously referred the BTB to the House by a vote of 48-0.

This update discusses the BTB’s provisions and what it conveys about the current U.S. legal climate around corruption and human rights sanctions, Congress’ increasingly activist sanctions posture, and the risk management and compliance inferences that U.S. and foreign financial institutions should draw from the Banking Transparency Bill when viewed in context.

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