New suspicious activity report (SAR) key term for reporting evasion of U.S. export controls
New key term when reporting potential efforts by individuals or entities seeking to evade U.S. export controls
New suspicious activity report (SAR) key term
The Bureau of Industry and Security (BIS) of the U.S. Department of Commerce and the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) today issued a joint notice [PDF 530 KB] highlighting a new suspicious activity report (SAR) key term for financial institutions to reference when reporting potential efforts by individuals or entities seeking to evade U.S. export controls not related to Russia’s invasion of Ukraine.
The new SAR key term is “FIN-2023-GLOBALEXPORT.”
According to today’s FinCEN release, the joint notice:
- Emphasizes the importance of financial institutions applying a risk-based approach to trade transactions and remaining vigilant against efforts by individuals or entities seeking to evade export controls globally
- Highlights global red flag indicators of export control evasion, with a focus on advanced and critical technologies that also can be applicable to due diligence efforts of exporters in addition to financial institutions
The notice applies to export control evasion occurring in support of other nation-state adversaries and illicit actors globally and provides U.S. financial institutions with red flags to assist them in identifying transactions potentially tied to the illicit acquisition of items subject to the Export Administration Regulations (EAR).
For more information, contact a professional with KPMG’s Trade & Customs services:
John L. McLoughlin
Luis (Lou) Abad
|Jenna Leigh Glass
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