Guidance on Potential Export Violations - Russia
FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security Urge Increased Vigilance for Potential Russian and Belarusian Export Control Evasion Attempts
The Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) are issuing a joint alert urging financial institutions to be vigilant against efforts by individuals or entities to evade BIS export controls implemented in connection with the Russian Federation’s (Russia) further invasion of Ukraine. This joint alert provides financial institutions with an overview of BIS’s current export restrictions; a list of commodities of concern for possible export control evasion; and select transactional and behavioral red flags to assist financial institutions in identifying suspicious transactions relating to possible export control evasion. This alert further reminds financial institutions of their Bank Secrecy Act (BSA) reporting obligations and details how suspected export control evasion activity may also be reported to BIS enforcement authorities.
Read the FinCEN & BIS Joint Alert 003
FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security Urge Continued Vigilance for Potential Russian Export Control Evasion Attempts
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) previously issued a joint alert (2022 Alert) urging financial institutions to be vigilant against efforts by individuals and entities to evade BIS export controls implemented in connection with the Russian Federation’s (Russia) further invasion of Ukraine. This supplemental joint alert provides financial institutions additional information regarding new BIS export control restrictions related to Russia, as well as reinforces ongoing U.S. Government engagements and initiatives designed to further constrain and prevent Russia from accessing needed technology and goods to supply and replenish its military and defense industrial base. This alert further details evasion typologies, highlights for financial institutions nine high priority.
Read the FinCEN & BIS Joint Alert 004
Cracking Down on Third-Party Intermediaries Used to Evade Russia-Related Sanctions and Export Controls
Over the year following Russia’s illegal and unprovoked war against Ukraine, the U.S. government has used its economic tools to degrade Russia’s economy and war machine. Along with international partners and allies, the Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS) have imposed sanctions and export controls of an unprecedented scope and scale in an effort to degrade Russia’s ability to wage its unjust war and to prevent it from taking military action elsewhere. The Department of Justice (DOJ) has matched these unprecedented restrictions with equally unprecedented enforcement efforts to aggressively prosecute those who violate U.S. sanctions and export control laws, led by the work of Task Force KleptoCapture.
Despite these efforts, malign actors continue to try to evade Russia-related sanctions and export controls. One of the most common tactics is the use of third-party intermediaries or transshipment points to circumvent restrictions, disguise the involvement of Specially Designated Nationals and Blocked Persons (SDNs) or parties on the Entity List in transactions, and obscure the true identities of Russian end users. This Note highlights several of these tactics to assist the private sector in identifying warning signs and implementing appropriate compliance measures.
Guidance on Potential Export Violations - Iran
Guidance to Industry on Iran’s UAV-Related Activities: Iran’s procurement, development, and proliferation of unmanned aerial vehicles (UAVs) is an increasing threat to international peace and security.
The Department of Commerce, the Department of Justice, the Department of State, and the Department of the Treasury are issuing this advisory to alert persons and businesses globally to the threat of Iran’s UAV-related activities and the need to take appropriate steps to avoid or prevent any activities that would support the further development of Iran’s UAV program.
Guidance of Industry on Iran's UAV-Related Activities