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