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On March 7, 2022, the Financial Crimes Enforcement Network (FinCEN) issued an alert, FIN-2022-Alert001, to remind financial institutions of reporting obligations related to convertible virtual currency (CVC) and provide red flags to assist in identifying potential Russian sanction evasion activity.
Seven red flag indicators were introduced in the alert for sanction evasion attempts using the U.S. financial system, including:
It also noted indicators that sanction evasion using CVCs might occur. In these instances the following might take place:
Financial institutions are reminded to be on high alert for possible ransomware attacks and other cybercrime as well in the wake of recent events.
It is important for financial institutions and money service businesses (MSBs) to identify and report suspicious activity associated with sanctions evasion and make use of Section 314(b) to share information related to identifying hidden Russian and Belarusian assets.
This publication is distributed for informational purposes only, with the understanding that Doeren Mayhew is not rendering legal, accounting, or other professional opinions on specific facts for matters, and, accordingly, assumes no liability whatsoever in connection with its use. Should the reader have any questions regarding any of the news articles, it is recommended that a Doeren Mayhew representative be contacted.
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