Notices to Members

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Notice I-22-09

March 09, 2022

FinCEN issues alert on potential Russian sanctions evasion efforts and reminds financial institutions of SAR and other reporting obligations

On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert reminding all financial institutions to be vigilant against efforts to evade the expansive sanctions (e.g., Office of Foreign Assets Control) and other U.S.-imposed restrictions implemented in connection with Russia's ongoing invasion of Ukraine. The alert contains examples of select red flag indicators to assist financial institutions in identifying potential sanctions evasions and reminds financial institutions of their Bank Secrecy Act reporting (e.g., suspicious activity report (SAR)) obligations. All NFA Members should carefully review the alert. A copy of the alert is available on FinCEN's website.

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