The Financial Crimes Enforcement Network (FinCEN) and the Department of Commerce’s Bureau of Industry and Security (BIS) have issued a joint notice calling for financial institutions to be vigilant against efforts by individuals or entities to evade Russia-related export controls administered by BIS.

The joint notice provides information on:

  • The new referencing term for Suspicious Activity Reports (SARs);
  • Applying a Risk-Based Approach to Trade Transactions;
  • Red Flag Indicators of Export Control Evasion; and
  • Relevant BSA Obligations for U.S. Financial Institutions regarding Suspicious Activity and Other BSA Reporting.

Firms with operations in or with the U.S. should review the FinCEN and BIS notice to ensure compliance with their reporting obligations.

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