FinCEN Flags Russian Attempts to Evade Sanctions

As the U.S. continues its crackdown against Russia over the recent invasion of Ukraine, the Financial Crimes Enforcement Network today called on financial institutions to be vigilant against attempts to evade the expansive sanctions and restrictions currently in place. The advisory noted that “sanctioned Russian and Belarusian actors may seek to evade sanctions through various means, including through non-sanctioned Russian and Belarusian financial institutions and financial institutions in third countries.”

FinCEN noted several red flag indicators that could signal attempted sanctions evasions, including several related to convertible virtual currency, noting that “sanctioned persons, illicit actors and their related networks or facilitators may attempt to use CVC and anonymizing tools to evade U.S. sanctions and protect their assets around the globe, including in the United States.”

According to FinCEN, banks should specifically watch for transactions initiated from IP addresses located in Russia, Belarus or other sanctioned jurisdictions; transactions connected to CVC addresses listed on the Office of Foreign Assets Control’s lists of specially designated nationals and blocked persons; and customer use of a CVC exchanger or foreign-located money service businesses in a high-risk jurisdiction.

The advisory also reminded institutions of dangers posed by Russian-related ransomware campaigns. The American Bankers Association continues to track developments related to the Russian invasion of Ukraine on its dedicated webpage on, and has also issued a staff analysis summarizing recent sanctions activity.