FinCEN Alerts of Possible Russian Sanctions Evasion Tries

US Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an Alert on 7 March 2022, advising financial institutions (FIs) to be vigilant against efforts to evade sanctions and other US-imposed restrictions implemented “in connection with the Russian Federation’s further invasion of Ukraine”, including economic pressure measures applied against Russia and Belarus.

The FinCEN 2022-Alert 001 draws attention to 13 “select red flag indicators” to assist FIs in identifying potential sanctions evasion activity and remind them of their Bank Secrecy Act (BSA) reporting obligations, including with respect to convertible virtual currency (CVC). For SAR Filings in this regard, FinCEN instructs financial institutions to “reference this Alert by including the key term ‘FIN-2022-RUSSIASANCTIONS’ in SAR field 2 (Filing Institution Note to FinCEN) and the narrative to indicate a connection between the suspicious activity being reported and the activities highlighted in this alert.”

In its release of this Alert, FinCEN stated that “sanctions evasion may occur through various means, including through currently unsanctioned Russian and Belarusian banks or other financial institutions that retain at least some access to the international financial system.”