Today, the Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) are issuing a supplemental joint alert urging continued vigilance on the part of U.S. financial institutions for potential attempts by Russia to evade U.S. export controls.
The alert reinforces ongoing U.S. Government engagements and initiatives designed to further constrain and prevent Russia from accessing needed technology and goods to supply and replenish its military and defense industrial base. The alert is one of several actions the U.S. Treasury as well as other U.S Government agencies are taking today to reaffirm the United States’ commitment to strengthening the unprecedented and coordinated sanctions and other economic measures taken to date to counter Russia’s capacity to wage its illegal aggression against Ukraine.
Today’s alert supplements the first FinCEN-BIS joint alert issued in June 2022 and provides information on new export control restrictions implemented since June 2022. It details evasion typologies, introduces nine new high priority Harmonized System codes to inform U.S. financial institutions’ customer due diligence, and identifies additional transactional and behavioral red flags to assist in identifying suspicious transactions relating to possible export control evasion. FinCEN urges U.S. financial institutions to consider these indicators and those set out in the 2022 alert, in determining whether an identified activity may be connected to Russia-related export control evasion.