FCC RegUpdate

On September 08, 2023, the Financial Crimes Enforcement Network (FinCEN) issued a Financial Trend Analysis (FTA) on patterns and trends contained in Bank Secrecy Act (BSA) reporting on suspected evasion of Russia-related export controls.”

To know more, read here: https://www.fcctimes.com/2023/09/08/fincen-reveals-nearly-1-billion-in-suspicious-activity-linked-to-evasion-of-russia-related-export-controls/

“The FTA is based on 333 SARs filed between June 28, 2022, and July 12, 2023. The SARs, 96% of which were filed by USA-based depository institutions, detailed nearly USD 1 billion in suspicious activity.”

Here are some notable findings from the report:

  • Despite the sanctions, companies primarily based in China, Hong Kong, the UK, Belgium, Germany, Singapore, the United Arab Emirates, and Turkey are selling US-origin products to consumers in Russia.
  • Sensitive items are probably being supplied to Russia by China, Hong Kong, Turkey, and the United Arab Emirates, with payments frequently going through correspondent accounts based in the US.
  • The majority of electronics firms, primarily in the United States and Hong Kong, are associated with Russian export control evasion.
  • Firms in the US, China, Hong Kong, and Singapore’s industrial machinery sector may be supplying Russia with machinery.

Top 10 Subject Countries and Count of Subject References in BSA Reports on Suspected Export Control Evasion:

  1. United States (976)
  2. Russia (322)
  3. China (130)
  4. Hong Kong (126)
  5. Turkey (49)
  6. UAE (43)
  7. United Kingdom (33)
  8. Canada (30)
  9. Singapore (30)
  10. Cyprus (17)