FinCEN, Commerce Department issue joint alert on Russia sanctions

The Financial Crimes Enforcement Network and the Commerce Department’s Bureau of Industry and Security today issued a supplemental joint alert urging continued vigilance on the part of U.S. financial institutions for potential attempts by Russia to evade export controls.

Among other things, the alert provides financial institutions additional information regarding new BIS export control restrictions related to Russia, highlights nine high-priority harmonized system codes to inform their customer due diligence and identifies additional transactional and behavioral red flags to assist in identifying suspicious transactions relating to possible export control evasion. It also requests that financial institutions continue to use the existing SAR code when submitting SARs specific to Russian export control evasion and reminds them of their Bank Secrecy Act reporting obligations.