Regulatory Alerts2023-05-19 | FIN-2023-Alert004Added
Supplemental Alert: FinCEN and BIS Urge Continued Vigilance for Potential Russian Export Control Evasion Attempts
Financial institutions are requested to reference alert FIN-2023-Alert004 in Suspicious Activity Report (SAR) field 2 and narratives using the key term FIN-2022-RUSSIABIS. The document identifies nine high-priority Harmonized System (HS) codes for customer due diligence and outlines evasion typologies involving third-party intermediaries, transshipment points, and shell companies. It reinforces existing Bank Secrecy Act reporting obligations and highlights new Bureau of Industry and Security export control restrictions targeting Russia's defense industrial base.
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