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Puerto Rico Takes Steps to Eradicate Financial Institution Risk Management Frameworks, Says Treasury Official

A recent meeting between Puerto Rico Governor Pedro Pierluisi and Brian Nelson, Under Secretary for Terrorism and Financial Intelligence at the US Department of the Treasury, has highlighted the island’s efforts to improve its financial institution risk management frameworks.

Recent Progress

According to Pierluisi, recent actions by the Puerto Rican government and legislature have taken the commonwealth off the high-risk list in the 2024 National Money Laundering Risk Assessment. The Office of the Commissioner of Financial Institutions (OCIF) has played a key role in strengthening its investigative unit, supervising regulated entities, and taking action against those that do not comply with applicable federal and state laws.

Regulatory Framework Improvements

Two mandates - Acts 44 and 45 of 2024 - were recently passed to improve the regulatory and supervisory framework for International Banking Entities (IBEs) and International Financial Entities (IFEs), aimed at combating money laundering. Commissioner Natalia Zequeira emphasized that these efforts have paid off, stating:

“It’s definitely positive news for Puerto Rico because it means that this financial sector that operates from the island is no longer considered nationally as a risk for the federal financial system… compliance and latent risk no longer exist.”

Treasury Official’s Praise

Nelson praised Puerto Rico’s progress during his first visit to the island, noting that Treasury’s oversight, including the 2024 National Money Laundering Risk Assessment, drives reforms. He expressed commitment to continuing support for law enforcement and regulatory agencies in Puerto Rico.

Challenges Ahead

Pierluisi acknowledged challenges faced by IBEs and IFEs in processing transactions due to US banks minimizing exposure risks by closing accounts. However, he remains committed to ensuring a compliant banking system on the island.

FinCEN’s Involvement

Nelson’s visit comes after that of Andrea Gacki, Director of the Financial Crimes Enforcement Network (FinCEN), who hosted the first-ever FinCEN Exchange in Puerto Rico earlier this year. The 2022 National Money Laundering Risk Assessment had identified increased risks in Puerto Rico due to the existence of cooperativas and IBEs/IFEs.

Enforcement Actions

The US Treasury’s Office of Foreign Assets Control found Nodus International Bank Inc., an IFE in Puerto Rico, in violation of Venezuelan sanctions in October 2022. In September 2023, FinCEN announced a $15 million civil penalty against Bancrédito International Bank and Trust Corp. for violations of the Bank Secrecy Act.

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