FinCEN alerts credit unions of potential Russian sanction evasion efforts
FinCEN issued FIN-2022-Alert001 to credit unions about the potential of sanction evasion activity. This alert warns credit unions the Russian government and sanctioned individuals may attempt to evade sanctions through the use of non-sanctioned financial institutions and financial institutions in other countries. In the alert, FinCEN has identified several red flag indicators that may help a credit union detect sanction evasion activities.
Sanction Evasion Attempts Using the U.S. Financial System
FinCEN has identified seven select red flag indicators that may improve a credit union’s detection of activity by parties, designed to circumvent sanctions.
- Use of corporate vehicles to hide (i) ownership, (ii) source of funds, or (iii) countries involved, particularly sanctioned jurisdictions