FIFA racketeering indictment could cause concern for banks

The US Department of Justice's FIFA indictment may require certain banks to review any of their FIFA-related transactions, as well as test their compliance policies and procedures relating to compliance with know-your-customer and anti-money laundering laws.  The indictment says the facilities of 26 banks were used to perpetrate the scheme. Although there is no suggestion that the banks are at fault, the indictment alleges that illegal payments may have been made through the banks or that illegal payments may have been kept at accounts held by the defendants with the banks.  This alert considers the legal responsibilities of banks in this context and outlines some proactive steps that banks can take.