On September 8, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) published a Financial Trend Analysis (“FTA”) highlighting trends related to suspected evasion of Russia-related export controls observed in reports required to be filed by financial institutions with FinCEN under the Bank Secrecy Act (“BSA”), such as through suspicious activity reports. The FTA highlights certain evasion red flags useful for purposes of companies’ own compliance efforts, while also serving as a…
On June 28, 2023, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the Office of Financial Sanctions Implementation of the HM Treasury (“OFSI”) jointly issued a Humanitarian Assistance and Food Security Fact Sheet (the “Fact Sheet”) to provide additional clarity on US and UK Russia-related sanctions in the context of humanitarian assistance and the export to Russia of agricultural commodities, medicines, and medical devices. The Fact Sheet provides US and…
On April 27, 2023, the US Department of State (“State”) designated Russia’s Federal Security Service (“FSB”) and Iran’s Islamic Revolutionary Guard Corps Intelligence Organization (“IRGC-IO”) pursuant to Executive Order (“EO”) 14078 (Bolstering Efforts To Bring Hostages and Wrongfully Detained United States Nationals Home), with the result that the IRGC-IO has been added to the Specially Designated Nationals and Blocked Persons List (“SDN List”). The IRGC as a whole and FSB were previously designated on the…
On January 25, 2023, the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an alert to financial institutions regarding potential investments in the US commercial real estate (“CRE”) sector by sanctioned Russian individuals, their family members, and entities through which they act (“Alert”). The Alert complements an earlier alert that FinCEN issued in March 2022, shortly after Russia invaded Ukraine. Our coverage of the March 2022 alert can be found here. In…