FINCEN AND THE BUREAU OF INDUSTRY AND SECURITY URGE INCREASED VIGILANCE FOR POTENTIAL RUSSIAN AND BELARUSIAN EXPORT CONTROL EVASION ATTEMPTS

An Alert from FinCEN and BIS on 28 June urges financial institutions to be vigilant against efforts by individuals or entities to evade BIS export controls implemented in connection with the Russia’s further invasion of Ukraine.  It further reminds financial institutions of their Bank Secrecy Act reporting obligations and details how suspected export control evasion activity may also be reported to BIS enforcement authorities.  It provides financial institutions with an overview of BIS’s current export restrictions; a list of commodities of concern for possible export control evasion; and select transactional and behavioural red flags to assist financial institutions in identifying related suspicious transactions. 

https://www.fincen.gov/sites/default/files/2022-06/FinCEN%20and%20Bis%20Joint%20Alert%20FINAL.pdf

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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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