The Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) have recently issued Joint Notice FIN-2023-NTC2 which presents a new reporting key term and highlights red flags relating to global evasion of U.S. export controls (the “Joint Notice”). This comes after two previous joint alerts were issued by these agencies, cautioning financial institutions (“FIs”) about attempts made by individuals or entities to evade Russia-related restrictions.
For more detailed information, you may refer to the Joint Notice and understand its nuances; it contains important information for legal professionals in the corporate sector, especially those providing advice related to global trade and compliance procedures.
FinCEN and BIS have been proactive in warning FIs about efforts associated with global evasion of American export controls. This can be observed from their prior joint alerts. Amidst a time where numerous multinational corporations extend their operations to every corner of the globe, it is imperative for FIs to thoroughly understand and comply with U.S. export control laws.
The issuance of Joint Notice FIN-2023-NTC2 underscores the U.S. governmental agencies’ determination to uphold regulations in the face of evasion attempts. Moreover, it serves as a reminder of their close monitoring on situations wherein contravention of these regulations may occur.
This alignment of FinCEN and BIS is critical to the enforcement of U.S. export control laws. Every non-compliance issue becomes a serious legal worry with potential for both financial and reputational damage.
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