FinCEN Highlights Data Trends in BSA Reports on Evasion of Russian Export Controls

FinCEN reported on trends in Bank Secrecy Act ("BSA") data related to suspected evasion of Russia-related export controls.

In a Financial Trend Analysis, FinCEN highlighted:

• U.S.-Origin Goods Supplied Directly and Indirectly to Russian End-Users. FinCEN said that an analysis of BSA reports revealed instances of U.S.-origin goods going to end-users in Russia, including Russian companies supporting military efforts in Ukraine. In some instances, U.S. companies were transacting directly with Russian counterparties, and in other instances U.S. companies were transacting with intermediaries located in other countries.
• Jurisdictions Likely Supplying Sensitive Goods to Russia. FinCEN identified China, Hong Kong, Turkey and the United Arab Emirates as jurisdictions in which there were significant numbers of transactions potentially involving sensitive goods being supplied to Russian end-users. FinCEN noted that transactions with companies in these jurisdictions often involve payments that flow through U.S.-based correspondent accounts.
• Electronics Equipment in Export Control Evasion-Related BSA Reports. FinCEN reported that companies identified in the BSA reports are frequently connected to the electronics industry. FinCEN stated that there were also companies within the industrial machinery industry that supplied equipment to Russia, such as fluid transfer system components, gas compressors and welding equipment.