Strengthening banking supervision in the world in connection with the war in Ukraine

US agencies, the Financial Crimes Enforcement Commission (FinCEN) and the Bureau of Industry and Security (BIS) of the US Treasury, have issued a circular calling for increased vigilance against attempts by Russia and Belarus to evade export controls.

This circular is addressed primarily to financial institutions. Therefore, we ask all our readers who have bank accounts in third countries to carefully read this article.

“The Financial Crime Enforcement Commission (FinCEN) and the U.S. Department of Commerce and Security (BIS) Bureau of Industry and Security (BIS) are announcing an increased alert urging financial institutions to be vigilant against attempts by individuals or entities to circumvent BIS export controls imposed in response to Russian aggression. (Russia) against Ukraine.

Transactional and Behavioral Alert Markers:

- The nature of the client's core business, the type of services or products offered, and geographic presence create additional risks of inadvertent participation in export control circumvention for Russia and Belarus.

- Transactions involving companies that have little presence on the Internet.

- Transactions related to changing shipments or payments that were previously scheduled to Russia or Belarus, or for companies located in Russia or Belarus, but which are now about to change the country of registration or change the company and country.

- Transactions related to payments made from persons located in third countries related to transactions from a “potential transshipment point” for exports to Russia and Belarus.

- Making last-minute changes to transactions related to a sender or recipient located in Russia or Belarus.

- Parties to transactions with addresses that appear inconsistent with business or are otherwise "problematic" (e.g. physical address does not exist or is residential)."

In total, 22 criteria for suspicion are presented in the circular, we have presented only a small part of them.

The document contains a list of so-called "transshipment points" through which, according to the American side, "limited or controlled exports to Russia or Belarus are carried out." These locations include but are not limited to Armenia, Brazil, China, Georgia, India, Israel, Kazakhstan, Kyrgyzstan, Mexico, Nicaragua, Serbia, Singapore, South Africa, Taiwan, Tajikistan, Turkey, the United Arab Emirates and Uzbekistan, the statement said. departments.

The document directs financial institutions to notify U.S. government authorities if they know, suspect, or have reason to suspect that a transaction made or undertaken by, in, or through a financial institution involves money derived from illegal activities or attempts to hide funds obtained as a result of illegal activities; is designed to circumvent regulations and has no real business or apparent legitimate purpose; or involves the use of a financial institution to facilitate criminal activity, including to circumvent sanctions or evade export controls.

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