FinCEN, Commerce: New Term for Reporting of Export Control Evasion

In a joint notice issued this week, the Financial Crimes Enforcement Network and the Commerce Department’s Bureau of Industry and Security announced a new reporting term, “FIN-2023-GLOBALEXPORT,” for financial institutions to reference when filing Suspicious Activity Reports related to global evasion of U.S. export controls beyond the Russia-related circumstances that were the subject of two previous notices. FinCEN and the BIS noted that financial institutions should continue to use the key term “FIN-2022-RUSSIABIS” when filing SARs related to potential Russia-related export control evasion.

The alert also provides a list of red flag indicators of export control evasion to assist financial institutions in identifying transactions potentially tied to evasion of U.S. export controls.