WASHINGTON, D.C. – Today, the Department of Commerce’s Bureau of Industry and Security
(BIS) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network
(FinCEN) issued a joint notice highlighting a new Suspicious Activity Report (SAR) key term
(“FIN-2023-GLOBALEXPORT”) for financial institutions to reference when reporting
potential efforts by individuals or entities seeking to evade U.S. export controls not related to
Russia’s invasion of Ukraine. FinCEN and BIS previously issued two joint alerts in June 2022
and May 2023 urging financial institutions to be vigilant against potential Russian export control
evasion in response to Russia’s illegal invasion of Ukraine. Financial institutions are encouraged
to continue to use the key term “FIN-2022-RUSSIABIS” when filing SARs related to suspected
Russian export control evasion.

The joint notice emphasizes the importance of financial institutions applying a risk-based
approach to trade transactions and remaining vigilant against efforts by individuals or entities
seeking to evade export controls, globally. This joint notice highlights global red flag indicators
of export control evasion, with a focus on advanced and critical technologies, that also can be
applicable to due diligence efforts of exporters in addition to financial institutions.
“Disrupting the diversion of critical U.S. technologies to nation-state adversaries and malign
actors around the globe is our highest priority,” said Assistant Secretary of Commerce for
Export Enforcement Matthew S. Axelrod. “This powerful new SAR key term will enable
even more BIS investigative and Entity List actions against global threats.”

“The purposeful evasion of U.S. export controls, regardless of where it occurs or the adversary it
supports, is a serious national security issue,” said FinCEN Director Andrea Gacki. “FinCEN
is proud to partner with BIS in issuing this Notice and providing financial institutions with a new
key term which they can use to file suspicious activity reports when they suspect such activity.”
BIS leverages SARs to investigate violations of U.S. export control regulations. Investigations
involving advanced technologies (e.g., advanced semiconductors, quantum, hypersonics) sought
by nation state adversaries to support military modernization efforts designed to overcome U.S.
military superiority, or mass surveillance programs that enable human rights abuses are being
prioritized and worked through the interagency Disruptive Technology Strike Force, co-led by
BIS and the Department of Justice.

The joint notice is part of the ongoing efforts by BIS and the U.S. Department of the Treasury to
strengthen export controls and prevent global evasion of U.S. export controls. By working
together and leveraging their respective expertise, BIS and FinCEN aim to disrupt illicit
acquisition activities and enhance the overall security and integrity of the international trade and
financial systems.

The full notice is available online here.

For more information, visit www.bis.doc.gov