FinCEN Reveals Nearly $1 Billion in Suspicious Activity Linked to Evasion of Russia-Related Export Controls

Today, the Financial Crimes Enforcement Network (FinCEN) released a Financial Trend Analysis (FTA) regarding patterns and developments discovered in Bank Secrecy Act (BSA) reports concerning suspected efforts to evade Russia-related export controls. The analyzed BSA reports, which follow previous joint Alerts on this issue, revealed nearly $1 billion in suspicious activity.

BIS relies on information from BSA reporting, prompted by the joint Alerts, to support investigations and identify parties in Russia and other countries acting against U.S. national security and foreign policy interests. This has led to their designation on the Entity List and the imposition of license requirements for transactions governed by the Export Administration Regulations, disrupting foreign parties’ ability to evade BIS export controls.

The FTA outlines several trends observed in the BSA reporting:

1. Suspicious transactions occurring after Russia’s invasion suggest that intermediary companies in various countries may have purchased U.S.-origin goods for Russian end-users.
2. Suspicious transactions indicate trade activities, likely involving sensitive items, connecting end users in Russia to other jurisdictions, particularly China, Hong Kong, and Turkey.
3. The majority of companies in the dataset are associated with the electronics industry and may be linked to, or directly involved in, Russian export control evasion.
4. Companies in the industrial machinery sector may also be supplying equipment to Russia.

FinCEN expects that as more individuals and entities are publicly identified in connection with the evasion of Russia-related export controls, new trends may emerge in BSA data.