On 6 November, The US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the US Department of Commerce’s Bureau of Industry and Security (“BIS”) issued their third joint alert regarding efforts by bad actors to evade international sanctions.
The alert suggests 13 red flags which may indicate export control evasion that financial institutions should be aware of. It also introduces a new Suspicious Activity Report (“SAR”) key term, “FIN-2023-GLOBALEXPORT” to...
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