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Treasury’s Financial Crimes Enforcement Network (FinCEN) and Commerce’s Bureau of Industry and Security (BIS) issued a joint alert on potential Russian and Belarusian attempts to evade US export controls. The alert directed to financial institutions outlines export controls implemented by BIS as a result of Russia’s invasion of Ukraine, commodities and ECCNs with a high risk of diversion, and red flags of sanction and export control evasion strategies.
Financial institutions should use risk assessment, risk mitigation, and due diligence measures when conducting business with export or import customers, according to the alert, and institutions must submit a Suspicious Activity Report (SAR) in certain instances. As a result, covered institutions may start sending or increase sending of requests for compliance related information to customers.
Not only is the alert a resource for understanding due diligence expectations of financial institutions, it also provides valuable information for exporters. Including the previously mentioned high risk commodities and red flags, identifying companies linked to the Russian state, and common transshipment countries used to evade export controls. Read the entire alert for all relevant information.