WASHINGTON—The Department of Commerce’s Bureau of Industry and Security (BIS) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) have issued a joint notice highlighting a new Suspicious Activity Report (SAR) key term.
The key term, “FIN-2023-GLOBALEXPORT,” is for financial institutions to reference when reporting potential efforts by individuals or entities seeking to evade U.S. export controls not related to Russia’s invasion of Ukraine, the agencies said.
FinCEN and BIS previously issued two joint alerts in June 2022 and May 2023 urging financial institutions to be vigilant against potential Russian export control evasion in response to Russia’s illegal invasion of Ukraine.
The agencies are encouraging financial institutions are encouraged to continue to use the key term FIN-2022-RUSSIABIS when filing SARs related to suspected Russian export control evasion.
Risk-Based Approach
“The joint notice emphasizes the importance of financial institutions applying a risk-based approach to trade transactions and remaining vigilant against efforts by individuals or entities seeking to evade export controls globally,” the agencies said. “This joint notice highlights global red flag indicators of export control evasion, with a focus on advanced and critical technologies, that also can be applicable to due diligence efforts of exporters in addition to financial institutions.”
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