US Agencies Issue Followup Alert on Russian Evasion Attempts

Further to their June 2022 release of a joint alert, US Treasury’s Financial Crimes Enforcement Network (FinCEN) and the US Department of Commerce’s Bureau of Industry and Security (BIS) issued a supplemental joint alert urging US financial institutions to exercise continued vigilance for potential attempts by Russia to evade US export controls.

The Supplemental Alert (FIN-2023-Alert004) dated 19 May 2023 reinforces US Government efforts to prevent Russia from accessing needed technology and goods for its military and defense industrial base and provides information on new export control restrictions implemented since June 2022.

The Supplemental Alert, to be used in conjunction with the 2022 Alert, addresses the impact of US sanctions and export controls against Russia, including a case study. It also details use of third-party intermediaries and transshipment points to evade controls, identifies nine Harmonized System (HS) codes for “High Priority Items” that Russia relies on for its weapons systems, and provides nine additional red flag indicators for institutions to watch for and consider when evaluating whether an identified activity may be connected to Russia-related export control evasion.