Regulatory Alerts2023-11-06 | FinCEN Notice FIN-2023-NTC2Added
FinCEN and BIS Announce New SAR Key Term and Red Flags for Global Export Control Evasion
FinCEN and the Bureau of Industry and Security establish the new Suspicious Activity Report key term "FIN-2023-GLOBALEXPORT" for U.S. financial institutions to use when reporting potential evasion of U.S. export controls beyond Russia-related circumstances. The notice provides specific red flag indicators, such as transactions involving entities with no web presence or items mismatching a purchaser's line of business, to assist in identifying suspicious activity tied to the illicit acquisition of items subject to the Export Administration Regulations. Financial institutions are instructed to include this key term in SAR field 2 and the narrative, check box 38(z) for "Export Evasion," and provide detailed information regarding involved products, entities, and financial instruments.