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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 11 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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<h2 class="wp-block-heading">Key Notes:</h2>
<ul class="wp-block-list">
<li>The May 2023 FinCEN/BIS Joint Alert supplements the Joint Alert published by FinCEN and BIS in June 2022.</li>
<li>The Supplemental Joint Alert offers financial institutions new and updated information on export control restrictions imposed by BIS related to Russia.</li>
<li>Included is a list of certain &ldquo;high priority&rdquo; items organized according to their Harmonized System (HS) Codes, which should prompt enhanced, risk-based customer and transactional due diligence.</li>
<li>Nine new transactional and behavioral &ldquo;red flags&rdquo; are highlighted which should be considered in addition to the 22 &ldquo;red flag&rdquo; indicators of illicit or suspicious activity that were enumerated in the June 2022 Joint Alert.</li>
<li>The Joint Alert requests that financial institutions continue using the existing SAR code&mdash;FIN-2022-RUSSIABIS&mdash;when submitting SARs specifically related to Russian export control evasion. </li>
<li>Financial institutions are reminded of their Bank Secrecy Act (BSA) reporting obligations as well.</li>
</ul>
<p>On May 19, 2023, the U.S. Department of the Treasury&rsquo;s Financial Crimes Enforcement Network (FinCEN) and the U.S. Department of Commerce&rsquo;s Bureau of Industry and Security (BIS) issued a <a href="https://www.bis.doc.gov/index.php/documents/enforcement/3272-fincen-and-bis-joint-alert-final-508c/file" target="_blank" rel="noreferrer noopener">Supplemental Joint Alert</a> reminding financial institutions to remain vigilant against individuals and entities attempting to skirt export controls related to Russia&mdash;a tool of economic statecraft maintained by BIS to advance U.S. national security and foreign policy interests&mdash;and to provide additional and updated information on &ldquo;ongoing U.S. Government engagements and initiatives designed to further constrain and prevent Russia from accessing needed technology and goods to supply and replenish its military and defense industrial base.&rdquo; The joint alert serves as an auxiliary to an earlier <a href="https://www.fincen.gov/sites/default/files/2022-06/FinCEN%20and%20Bis%20Joint%20Alert%20FINAL.pdf" target="_blank" rel="noreferrer noopener">FinCEN/BIS Joint Alert</a> published in June 2022. </p>
<p><strong>View this full client update in <a href="https://www.thompsonhine.com/insights/fincen-and-bis-issue-supplemental-joint-alert-to-reinforce-continued-vigilance-of-potential-russian-export-control-evasion-attempts/" target="_blank" rel="noreferrer noopener">HTML</a> or <a href="https://admin.thompsonhine.com/wp-content/uploads/2023/06/FinCEN-and-BIS-Issue-Supplemental-Joint-Alert-to-Reinforce-Continued-Vigilance-of-Potential-Russian-Export-Control-Evasion-Attempts.pdf" target="_blank" rel="noreferrer noopener">PDF</a> format.</strong></p>

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SmarTrade

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Francesca M.S. Guerrero

Samir D. Varma

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Aaron C. Mandelbaum

Senior Legislative and Regulatory Policy Advisor

Scott E. Diamond

International Trade

FinCEN & BIS Issue Joint Alert Encouraging Continued Vigilance Regarding Potential Russia Export Control Evasion