Key Notes:

  • The May 2023 FinCEN/BIS Joint Alert supplements the Joint Alert published by FinCEN and BIS in June 2022.
  • The Supplemental Joint Alert offers financial institutions new and updated information on export control restrictions imposed by BIS related to Russia.
  • Included is a list of certain “high priority” items organized according to their Harmonized System (HS) Codes, which should prompt enhanced, risk-based customer and transactional due diligence.
  • Nine new transactional and behavioral “red flags” are highlighted which should be considered in addition to the 22 “red flag” indicators of illicit or suspicious activity that were enumerated in the June 2022 Joint Alert.
  • The Joint Alert requests that financial institutions continue using the existing SAR code—FIN-2022-RUSSIABIS—when submitting SARs specifically related to Russian export control evasion.
  • Financial institutions are reminded of their Bank Secrecy Act (BSA) reporting obligations as well.

On May 19, 2023, 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) issued a Supplemental Joint Alert reminding financial institutions to remain vigilant against individuals and entities attempting to skirt export controls related to Russia—a tool of economic statecraft maintained by BIS to advance U.S. national security and foreign policy interests—and to provide additional and updated information on “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.” The joint alert serves as an auxiliary to an earlier FinCEN/BIS Joint Alert published in June 2022.

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