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On March 7, 2022, the US Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued an alert to financial institutions warning about potential attempts to evade US sanctions and other restrictions imposed on Russia and Belarus (“Alert”). The Alert includes red flags that financial institutions should review to help identify potential attempts to avoid sanctions, with a particular focus on convertible virtual currency (“CVC”), and also reminds companies of their reporting obligations under the Bank Secrecy…

On February 24, 2022, the Bureau of Industry and Security (“BIS”) within the US Commerce Department (“Commerce”) issued a final rule (“Final Rule”) effective immediately that implements a sweeping series of new export control measures under the Export Administration Regulations (“EAR”) against Russia. Commerce’s press release regarding these new controls can be found here. These new US export control measures primarily target Russia’s defense, aerospace, and maritime sectors and are intended to curtail Russia’s ability…