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 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…
On October 1, 2020, the US Department of the Treasury (“Treasury”) issued a pair of advisories to alert companies about risks associated with ransomware scams and attacks. Ransomware is malicious software designed to block access to a computer system or data, often by encrypting data or programs on information technology systems to extort ransom payments from victims in exchange for decrypting the information and restoring victims’ access to their systems or data. The advisories suggest that…
On October 25, 2019, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule identifying Iran as a jurisdiction of primary money laundering concern (“Final Rule”) under Section 311 of the USA PATRIOT ACT, seeking to further isolate Iran from the global financial system. Concurrently, the US Treasury and State Departments announced a new humanitarian mechanism to ensure that funds associated with permissible trade in support of the Iranian people are not diverted by the Iranian regime to develop ballistic missiles, support terrorism, or finance other malign activities. These measures build upon the US Treasury Department’s Office of Foreign Assets Control’s (“OFAC”) additional sanctions against the Central Bank of Iran discussed in our prior blog post here.