RegAlert2023-05-19 | FIN-2023-Alert004Added · Updated
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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- BIS advances U.S. national security, foreign policy, and economic objectives by ensuring an effective export control
and treaty compliance system and by promoting continued U.S. leadership in strategic technologies. See generally, Bureau of Industry and Security | U.S. Department of Commerce. - See FinCEN, “FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security Urge Increased
Vigilance for Potential Russian and Belarusian Export Control Evasion Attempts” (2022 Alert) (June 28, 2022). For other FinCEN alerts related to Russia’s invasion of Ukraine, see “FinCEN Advises Increased Vigilance for Potential Russian Sanctions Evasion Attempts” (Mar. 7, 2022); “FinCEN Alert on Real Estate, Luxury Goods, and Other HighValue Assets Involving Russian Elites, Oligarchs, and their Family Members” (Mar. 16, 2022); and “FinCEN Alert on Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites, Oligarchs, and Their Proxies” (Jan. 25, 2023). For further reference, see also FinCEN “Advisory on Kleptocracy and Foreign Public Corruption” (Apr. 14, 2022), which includes a discussion of Russian political corruption. - See 31 U.S.C. § 5312(a)(2); 31 C.F.R. § 1010.100(t).
- See U.S. Department of the Treasury (Treasury) Press Releases, “Remarks by Assistant Secretary for Terrorist
Financing and Financial Crimes Elizabeth Rosenberg at Program on International Financial Systems (PIFS) U.S. – Europe Symposium in Frankfurt, Germany” (May 11, 2023); “READOUT: Under Secretary Nelson’s Travel to Europe” (Apr. 23, 2023); “Remarks by Under Secretary Brian Nelson at American Chamber of Commerce Austria Roundtable” (Treasury Under Secretary Nelson Remarks) (Apr. 21, 2023); “JOINT READ OUT: US-EU-UK Sanctions Evasion Meeting with Private Sector Participants” (Apr. 13, 2023); and “READOUT: G7 Enforcement Coordination Mechanism Deputies Meeting” (Apr. 27, 2023); and White House Press Release, “G7 Leaders’ Statement” (Feb. 24, 2023). See also BIS Press Release, “Remarks as Prepared for Delivery by Assistant Secretary for Export Enforcement Matthew S. Axelrod to the 12th Annual Forum on U.S. Export & Re-export Compliance for Canadian Operations” (Jan. 31, 2023). FIN-2023-Alert004 May 19, 2023 Supplemental Alert: FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security Urge Continued Vigilance for Potential Russian Export Control Evasion Attempts The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS)1
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Source: Financial Crimes Enforcement Network — original document · Summary generated with machine assistance and reviewed before publication; the authoritative text is the regulator's original document. How RegAlert works
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