The United States has implemented expansive sanctions and other imposed restrictions in connection with the Russian Federation’s invasion of Ukraine. In committed support of Ukraine, the United States, along with allies and partners in Europe and around the globe, has imposed economic pressure on Russia and Belarus. In recent weeks, sanctions on oligarchs, politicians and related persons; restrictions on imports; and blocking of assets continue to take form as the invasion persists. As financial institutions, we are reminded to remain attentive to any sanction evasion efforts and of Bank Secrecy Act reporting obligations. Continue to consult the Office of Foreign Assets and Control’s (OFAC’s) website for detailed information on sanction actions.
The Financial Crimes Enforcement Network (FinCEN) has issued two recent alerts on potential Russian sanction evasion attempts. Items of value, such as real estate, luxury goods, and other high-value assets, can be used as a medium for exchange or investments to evade sanctions or imposed restrictions used by corrupt foreign “politically exposed persons” (PEPs) or their proxies. Evasion activities could be performed by a variety of actors, not limited to PEPs, and through non-sanctioned Russian and Belarusian financial institutions and third countries.
Red flags to look for
There are several red flags credit union staff should be looking for to identify potential evasion attempts. (For the complete list, please refer to FinCEN alert FIN-2022-Alert001 and FIN-2022-Alert002 and advisory FIN-2008-A003.)
Corporate One’s annual BSA/AML and OFAC training with ProBank’s Mark Dever
ProBank’s Mark Dever is back again this year with his usual flair to efficiently and cost-effectively help BSA/AML officers and compliance professionals meet the FFIEC’s expected training guidelines. This “BSA basics” webinar will cover the following topics: currency transaction reporting, Office of Foreign Asset Control, audit, suspicious activity reporting, member due diligence, risk assessment, “beneficial ownership,” and more.
Date: May 4
Time: 1:00 – 4:00 p.m. ET
Defining “items of value”
As your credit union looks for the red flags, it will be helpful to keep in mind the following explanations of several items of value that can be used as a medium for exchange or investments to evade sanctions or imposed restrictions.
Precious metals, stones, and jewelry
Other high-value assets
If your credit union identifies any potential evasion attempts, you are reminded to:
Kinya Knight, AVP
BSA/AML Compliance Manager