Alert encourages financial institutions to be vigilant amid war in Ukraine

Financial institutions are being urged to be vigilant against potential efforts to evade the expansive sanctions and other U.S.-imposed restrictions implemented in connection with Russia’s invasion of Ukraine, the U.S. Treasury Department’s Financial Crimes Enforcement Network, FinCEN, warned on Monday.

A FinCEN alert provides red flags to assist financial institutions in identifying potential sanctions evasion activity and reminds them of their Bank Secrecy Act reporting obligations, including with respect to convertible virtual currency, known as CVC.

The agency is encouraging all financial institutions — including those with visibility into cryptocurrency or CVC flows, such as CVC exchangers and administrators — to identify and report suspicious activity associated with potential sanctions evasion quickly and conduct appropriate, risk-based customer due diligence or enhanced due diligence where required.  Financial institutions are also encouraged to make full use of the information sharing authorities provided by Section 314(b) of the USA PATRIOT Act, according to FinCEN.

“In the face of mounting economic pressure on Russia, it is vitally important for U.S. financial institutions to be vigilant about potential Russian sanctions evasion, including by both state actors and oligarchs,” said Him Das, FinCEN’s acting director. “Although we have not seen widespread evasion of our sanctions using methods such as cryptocurrency, prompt reporting of suspicious activity contributes to our national security and our efforts to support Ukraine and its people.”

Ukraine Credit Union Displacement Fund
The Worldwide Foundation for Credit Unions has established the Ukraine Credit Union Displacement Fund. Text CUS4UKRAINE to 44-321 to donate, or visit the Worldwide Foundation for Credit Unions website.

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