In the aftermath of Russia’s invasion of Ukraine, the U.S. Financial Crimes Enforcement Network (“FinCEN”) and the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) have issued a joint alert, coupled with a supplemental alert. This call to attention seeks to encourage U.S. financial institutions to stay vigilant to potential attempts by Russia to sidestep U.S. sanctions and export controls, as reported by Ballard Spahr LLP on JD Supra.
The joint alert underlines the obligation of financial institutions to file suspicious activity reports (“SAR”s) when they suspect dodgy export control practices. The aim of the alert is not just to nudge the institutions into playing their part in securing export control, but also to facilitate FinCEN in building an overall picture regarding patterns and trends in evasion strategies.
Legal experts and corporate law professionals keeping an eye on global finance must pay keen attention to this issue. The potential implications of breaches in export controls could have far-reaching effects on the global economy and particularly, on the organizations involved.
Remaining well-informed and maintaining a proactive approach to such alerts could be effective for both preventing inadvertent legal breaches and for spotting potential threats.