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FinCEN Report Highlights Trends in Evasion of Russia-Related Export Controls

Recent Regulations & NewsFinCEN Report Highlights Trends in Evasion of Russia-Related Export Controls

Today, the Financial Crimes Enforcement Network (FinCEN) has released a Financial Trend Analysis (FTA) report focusing on patterns and trends derived from Bank Secrecy Act (BSA) reports concerning suspected efforts to evade Russia-related export controls. The BSA reports under examination were submitted in response to prior joint Alerts on this matter and collectively indicate nearly $1 billion in suspicious activities.

BIS employs the information from BSA reporting filed in response to joint Alerts to provide leads to their export enforcement agents. This assists in initiating new investigations and supporting existing ones. BIS also leverages the insights gained from BSA reporting to identify individuals and entities in Russia and other countries acting in opposition to U.S. national security and foreign policy interests. This can result in their inclusion on the Entity List and the imposition of license requirements for transactions subject to the Export Administration Regulations. These efforts disrupt the capacity of foreign parties to evade BIS export controls.

The FTA outlines several trends observed in the BSA reporting:

  1. Suspicious transactions carried out post-Russia’s invasion indicate that intermediary companies in various countries seem to have procured U.S.-origin goods on behalf of Russian end-users.
  2. Suspicious transactions connect trade activities, potentially involving sensitive items, between end users in Russia and other jurisdictions, with particular focus on China, Hong Kong, and Turkey.
  3. The majority of companies in the dataset are associated with the electronics industry and may be involved in or enabling Russian export control evasion.
  4. Companies in the industrial machinery sector may also be supplying Russia with equipment.

FinCEN anticipates that new trends in BSA data may surface as more individuals and entities are publicly identified as potentially connected to efforts to evade Russia-related export controls.

For official guidance to financial institutions regarding reporting suspicious activities related to Russia-linked entities, refer to FinCEN’s resource page on advisories at


By FCCT Editorial Team

Disclaimer: The views expressed in this article are independent views solely of the author(s) expressed in their private capacity.

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