The Financial Crimes Enforcement Network (FinCEN) issued an Alert yesterday highlighting the possibility of Russia and Belarus attempting to evade newly imposed sanctions through unsanctioned financial institutions with access to the international financial system.
The Alert highlights red flags, including those related to crypto, to be on the lookout for, and reminds financial institutions of their reporting obligations under the Bank Secrecy Act (BSA).
Scenarios that should be treated as red flags;
Special attention is called to quickly identifying and reporting such activities. In this regard, FinCEN reminds obliged entities of their Due Diligence obligations and the SAR filing process, urging the inclusion of the key term “FIN-2022-RUSSIA SANCTIONS”, as well as the importance of information sharing between financial institutions as authorized by section 314(b) of the USA PATRIOT Act.
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