READOUT: FinCEN Exchange Brings Together Public and Private Sectors to Discuss Attempts by Russia to Evade Export Controls

WASHINGTON—On November 16, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control, along with the Department of Commerce’s Bureau of Industry and Security (BIS), co-hosted a virtual FinCEN Exchange to discuss attempts by Russia to evade export controls. The Exchange included representatives from small- to mid-size financial institutions, law enforcement, and government agencies.

FinCEN Exchanges enhance law enforcement feedback and help financial institutions more effectively implement their anti-money laundering programs. This FinCEN Exchange exemplified the ongoing U.S. Government effort to further constrain and prevent Russia from accessing the international financial system and conduct economic activity to fund its invasion of Ukraine. FinCEN has issued the following information on this topic to provide red flags to assist financial institutions in identifying suspected illicit activity:

• FinCEN Alert on Increased Vigilance for Potential Russian Sanctions Evasion Attempts (March 7, 2022)
• FinCEN Alert on Real Estate, Luxury Goods, and Other High Value Assets Involving Russian Elites, Oligarchs, and their Family Members (March 16, 2022)
• First FinCEN-BIS Joint Alert Urging Increased Vigilance for Potential Russian and Belarusian Export Control Evasion Attempts (June 28, 2022)
• Financial Trend Analysis on Financial Activity by Russian Oligarchs (December 22, 2022)
• FinCEN Alert on Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites, Oligarchs, and Their Proxies (January 25, 2023)
• FinCEN-BIS Supplemental Joint Alert Urging Continued Vigilance for Potential Russian Export Control Evasion Attempts (May 19, 2023)
• Financial Trend Analysis on Suspected Evasion of Russian Export Controls (September 8, 2023)
• FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security Notice Announcing New Reporting Key Term and Highlight Red Flags Relating to Global Evasion of U.S. Export Controls (November 6, 2023)

FinCEN appreciates the critical support that financial institutions provide to law enforcement and national security agencies in fighting illicit activities through their suspicious activity reporting and their allocation of resources to national security priorities. FinCEN also strongly encourages all financial institutions to register under USA PATRIOT Act Section 314(b) and to form associations to engage in voluntary information sharing. Section 314(b) information sharing can reveal networks of illicit activity that no single financial institution can detect alone, compounding the benefits for both the financial institution and law enforcement. In fiscal year 2023, there were more than 7,600 314(b) registered financial institutions, making extensive network analysis possible.

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FinCEN Exchange is a voluntary public-private partnership that convenes relevant stakeholders, including law enforcement agencies and financial institutions. FinCEN Exchange aims to protect our national security and our citizens from harm by combatting money laundering and its related crimes, including terrorism, through public-private dialogue that encourages, enables, and acknowledges industry focus on high-value and high-impact activities.