On November 6, 2023, a vital joint notice was notably released by 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”). The notice concerned the introduction of a new Suspicious Activity Report (“SAR”) reporting term, efficiently named “FIN-2023-GLOBALEXPORT.”
This new term is of particular importance to all financial institutions governed by the Bank Secrecy Act (“BSA”). From now on, these institutions will be mandatorily obliged to utilize “FIN-2023-GLOBALEXPORT” while filing SARs. The reports that must carry the new term involve cases hinting at initiatives by individuals who might be attempting to subvert global export controls.
Obviously, this stands to be quite a substantial move towards promoting greater transparency within the financial landscape, and it further underscores the U.S. government’s commitment towards precluding attempts at global export control evasion.
Despite the bureaucratic simplicity, the symbolic weight of “FIN-2023-GLOBALEXPORT” is not to be underestimated. Its implementation signals a greater turn towards vigilance, accountability, and stringent adherence to both national and international regulations.
It is advisable for legal experts and professionals operating within the banking and finance sectors to pay close attention to these evolving phenomena. Understanding the nuances of such bureaucratic changes may be instrumental in ensuring compliance, thereby avoiding potential pitfalls associated with violations.
Interested readers can consult the full original notice at BIS and FinCEN Release Joint Notice Concerning Global Export Control Evasion.
Article written by: The Volkov Law Group