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ARTICLE · 30 MARCH 2022

FinCEN Identifies Red Flags Following Russia Sanctions

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On March 7, 2022, the US Financial Crimes Enforcement Network ("FinCEN") issued an alert advising all financial institutions to be vigilant against efforts to evade US sanctions and other restrictions...

GlobalInternational Law
Brad Resnikoff
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On March 7, 2022, the US Financial Crimes Enforcement Network ("FinCEN") issued an alert advising all financial institutions to be vigilant against efforts to evade US sanctions and other restrictions imposed in response to the Russian Federation's invasion of Ukraine.1 FinCEN's alert also identifies red flag indicators. This Legal Update summarizes some of the key points that FinCEN highlighted to assist financial institutions in identifying suspected sanctions evasion activity.

Background

Since February 2022, following the invasion of Ukraine by Russia, the US Department of the Treasury's Office of Foreign Assets Control ("OFAC") has implemented several sanctions actions related to the Russian financial services sector pursuant to Executive Order 14024.2 OFAC has also imposed sanctions on Russian Federal President Vladimir Putin, Minister of Foreign Affairs Sergei Lavrov, and 24 Belarusian individuals and entities who supported and facilitated the Russian

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