FinCEN Advises Increased Vigilance for Potential Russian Sanctions Evasion Attempts - Key Term FIN-2022-RUSSIASANCTIONS and SAR Guidance

Sep 18, 2026

Uploaded by Finn

FinCEN alerts financial institutions to remain vigilant against attempts to evade expansive U.S. sanctions and other restrictions tied to Russia’s further invasion of Ukraine. The notice instructs institutions to reference the alert in Suspicious Activity Report (SAR) filings, using the key term “FIN-2022-RUSSIASANCTIONS” in SAR field 2 and in the narrative. It outlines red flags, reinforces Bank Secrecy Act reporting and risk-based due diligence expectations, and encourages information sharing under Section 314(b) while noting recent Treasury and OFAC actions.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages10

Reading Time25 min

AccessFree to download

Overview of Recent Treasury Actions Responding to the Further Invasion of Ukraine

Sanctions Evasion Attempts Using the U.S. Financial System

Suspicious Activity Report (SAR) Filing Request and Key Term

Reminder of Relevant BSA Obligations and Information Sharing

FIN-2022-Alert001 March 7, 2022 FinCEN Advises Increased Vigilance for Potential Russian Sanctions Evasion Attempts The Financial Crimes Enforcement Network (FinCEN) is alerting all financial institutions1 tobe vigilant against efforts to evade the expansive sanctions and other U.S.-imposed restrictions implemented in connection with the Russian Federation’s further invasion of Ukraine.2 The United States is committed to supporting Ukraine, and, along with key U.S. partners and allies around the Suspicious Activity Report (SAR) filing request FinCEN requests financial institutions reference this alert in SAR field 2 (Filing Institution Note to FinCEN) and the narrative by including the following key term: “FIN-2022-RUSSIASANCTIONS” globe, has imposed unprecedented economic pressure measures on Russia and Belarus. This alert provides select red flags3 to assist in identifying potential sanctions evasion activity and reminds financial institutions of their Bank Secrecy Act (BSA) reporting obligations, including with respect to convertible virtual currency (CVC) . It is critical that all financial institutions, including those with visibility into CVC flows, such as CVC exchangers and administrators—generally considered money services businesses (MSBs)4 under the BSA—identify and quickly report suspicious activity associated with potential sanctions evasion, and conduct appropriate risk-based customer due diligence or, where required, enhanced due diligence (see Reminder of Relevant BSA Obligations below) . FinCEN also strongly encourages all financial institutions to make full use of their ability to share information consistent with Section 314(b)5 of the USA PATRIOT Act,6 and consider how the use of innovative tools and solutions may assist in identifying hidden Russian and Belarusian assets.7 1. See 31 U.S.C. § 5312(a)(2); 31 CFR § 1010.100(t) . 2. For relevant U.S. Department of the Treasury Office of Foreign Asset Control (OFAC) actions against the Russian Federation and the Republic of Belarus, see OFAC Recent Actions | U.S. Department of the Treasury. For additional information on compliance with OFAC obligations, see the Summary of Relevant OFAC Compliance Obligations section of this alert. For relevant U.S. Department of Commerce Bureau of Industry and Security actions, see U.S. Department of Commerce. For relevant U.S. Department of State actions, see U.S. Department of State. For other relevant U.S. government measures and actions, see The White House. 3. Many of the red flag indicators highlighted in this alert were previously identified in other FinCEN advisories and represent only a sampling of indicators of possible sanctions evasion activity and should not be considered an exhaustive list. Further, because no single financial red flag indicator is determinative of illicit or suspicious activity, financial institutions should consider the relevant facts and circumstances of each transaction, in keeping with their risk-based approach to compliance. 4. See FinCEN Guidance,“Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies,”(May 9, 2019) . 5. See 31 CFR § 1010.540. 6. See Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (‘‘USA PATRIOT Act’’) (Pub. L. 107–56) . 7. See Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, FinCEN, National Credit Union Administration, and Office of the Comptroller of the Currency,“Joint Statement on Innovative Efforts to Combat Money Laundering and Terrorist Financing,”(December 3, 2018) . Overview of Recent Treasury Actions Responding to the Further Invasion of Ukraine Since February 2022, and in response to Russia’s further invasion of Ukraine, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has taken several significant sanctions actions related to the Ru

FAQs

What does FinCEN ask financial institutions to do regarding sanctions evasion risk?

FinCEN requests that institutions stay vigilant against efforts to evade sanctions and identify suspicious activity tied to potential sanctions evasion, including through risk-based customer due diligence or enhanced due diligence where required.

How should the alert be referenced in a Suspicious Activity Report (SAR)?

FinCEN instructs institutions to reference the alert in SAR field 2 (Filing Institution Note to FinCEN) and include the key term “FIN-2022-RUSSIASANCTIONS” in the narrative.

What is the purpose of the provided red flag information?

The alert provides selected red flags to assist in identifying potential sanctions evasion activity and reminds institutions of Bank Secrecy Act reporting obligations, but it emphasizes that the list is not exhaustive and no single indicator is determinative.

Sep 18, 2026

Uploaded by Finn