Financial Crime World

Financial Crimes Enforcement Network Uncovers $1 Billion in Suspicious Activity Linked to Russia’s Export Controls Evasion

Washington, September 8, 2023 - FinCEN Releases Financial Trend Analysis (FTA) on Suspected Evasion of Russia-Related Export Controls

The Financial Crimes Enforcement Network (FinCEN) has released a Financial Trend Analysis (FTA) revealing patterns and trends in Bank Secy Act (BSA) reporting on suspected evasion of Russia-related export controls. The analysis found nearly $1 billion in suspicious activity, highlighting the efforts of financial institutions to provide critical intelligence leads and indications of potential Russia-related export control violations.

Joint Alerts Issued by FinCEN and BIS

The FTA is based on BSA reports filed in response to joint Alerts issued by FinCEN and the US Department of Commerce’s Bureau of Industry and Security (BIS) following Russia’s invasion of Ukraine. The alerts urged vigilance among US financial institutions regarding attempts by Russia to evade US export controls.

Acting FinCEN Director Comments

“We appreciate our strong partnership with financial institutions, which has led to significant financial intelligence leads and indications of potential Russia-related export control violations,” said Acting FinCEN Director Himamauli Das.

BIS Leverages BSA Reporting Data

The BIS leverages information from the BSA reporting to provide leads to their export enforcement agents, supporting new investigations and preexisting ones. The agency also uses this data to identify parties in Russia and third countries acting against US national security and foreign policy interests, leading to designation on the Entity List and imposition of license requirements for transactions subject to the Export Administration Regulations.

  • Suspicious Transactions after Russia’s Invasion: Companies in intermediary countries purchased U.S.-origin goods on behalf of Russian end-users.
  • Trade Activity between End Users: Suspicious transactions link trade activity between end users in Russia and other jurisdictions, particularly China, Hong Kong, and Turkey.
  • Electronics Industry Involvement: The majority of companies linked to the dataset are associated with the electronics industry and potentially facilitate Russian export control evasion.
  • Industrial Machinery Industry Supplying Russia: Companies in the industrial machinery industry may be supplying Russia with equipment.

FinCEN anticipates that new trends in BSA data may emerge as more individuals and entities are publicly identified as being connected to evasion of Russia-related export controls.