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US Commerce, Treasury Departments Outline Russian Sanctions Evasion Strategies

U.S. officials updated financial institutions in an advisory Friday on strategies they should use to guard against evasion of controls that prevent Russia from obtaining “low-technology consumer goods” and “critical components” in support of the country’s full-scale invasion of Ukraine.

The 12-page advisory, which the U.S. Treasury’s Financial Crimes Enforcement Network and Commerce Department’s Bureau of Industry and Security issued jointly, identifies new transactional characteristics and “behavioral red flags” that may indicate attempts to circumvent export bans and other restrictions, including by parties linked to Iran and China.

“Russia has lost over 10,000 pieces of equipment on the battlefield and is struggling to replace them,” the bureaus noted in the advisory, which updates a 10-page alert they issued in June 2022, four months into the invasion. “This has resulted in Russia tasking its intelligence services with finding ways to circumvent sanctions and export controls to replace needed equipment.”

When vetting corporate clients involved in trading integrated circuits and other “high-priority” products, financial institutions should review the dates of their incorporation, determine whether their physical locations and public websites raise any red flags, and evaluate the end users and intended uses of any goods they acquire or ship, the bureaus instructed. may update this coverage as more information becomes available.
Topics : Sanctions , Anti-money laundering
Source: U.S.: FinCEN
Document Date: May 19, 2023