Alert urges banks to be vigilant against efforts to evade export controls imposed on Russia

Banks and other financial institutions should be “vigilant” against efforts by those attempting to evade export controls in connection with Russia’s further invasion of Ukraine, two federal agencies said in an alert issued Tuesday.

In a joint statement, the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) said that by identifying and reporting suspicious activity indicative of efforts to efforts to evade BIS export controls implemented in connection with Russia’s invasion of Ukraine, “financial institutions contribute to U.S. and international efforts to degrade Russia’s military capabilities, apply economic pressure, and end the war in Ukraine.”

The agencies said the alert offers financial institutions an overview of BIS’s export restrictions to date, a list of certain commodities of concern, and other information they can use and incorporate into their risk-based screening of financial transactions.

The alert also provides, the agencies said, select transactional and behavioral red flag indicators of export control evasion, including red flags derived from recent Bank Secrecy Act (BSA) reporting.

FinCEN and BIS Issue Joint Alert on Potential Russian and Belarusian Export Control Evasion Attempts