FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) have published a joint alert urging financial institutions to remain vigilant against potential Russian export control evasion attempts.

The alert provides information and guidance to firms on:

  • Impact of U.S sanctions and export controls against Russia;
  • New export control restrictions implemented since the publication of FinCEN’s June 2022 alert;
  • Use of third-party intermediaries and transshipment points to evade controls;
  • The high priority items list by ‘Harmonized System Code’, a system developed by BIS covering nine critical U.S components that Russia relies on for its weapons systems;
  • Applying a risk-based approach to trade finance;
  • Select red flag indicators of export control evasion; and
  • Reminders of relevant BSA obligations for U.S financial institutions.

Firms can read the FinCEN-BIS release to remain alert to potential sanction evasion attempts and how to combat them.

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