By: Brian Taylor, Financial Institution Specialist

Due to the events unfolding in the Ukraine and the removal of Russia from SWIFT, Russian elites have been attempting to move large amounts of currency through world banking channels in subversive ways. In an attempt to thwart the evasion of such sanctions, FinCEN has released an advisory that details possible red flags for Russian sanctions evasion. FinCEN also asks that any SARs filed for Russian sanctions evasion reference the alert in SAR field 2 and the narrative with the following key term “FIN-2022-RUSSIASANCTIONS”. Financial institutions were encouraged to utilize 314(b) information sharing to help identify hidden Russian and Belarusian assets. See the attached alert for more details.
 
https://www.fincen.gov/sites/default/files/2022-03/FinCEN%20Alert%20Russian%20Sanctions%20Evasion%20FINAL%20508.pdf

By: Jeremy Clifton, CRCM, CAMS

On March 10, 2022, the Financial Action Task Force (FATF) published its most current lists of Jurisdictions under Increased Monitoring (grey list countries) and High-Risk Jurisdictions Subject to a Call for Action (black list countries). Financial institutions should ensure that transactions to or from these geographic areas are monitored and that AML system parameters are updated as needed. You can read the full press release here:

Financial Action Task Force Identifies Jurisdictions with Anti-Money Laundering and Combating the Financing of Terrorism and Counter-Proliferation Deficiencies | FinCEN.gov