FinCEN issues new SAR term for reporting export control evasion

The Financial Crimes Enforcement Network and the Bureau of Industry and Security issued a joint notice highlighting a new Suspicious Activity Report key term.

New Key Term: The “FIN-2023-GLOBALEXPORT” term is for financial institutions to reference when reporting potential efforts by individuals or entities seeking to evade U.S. export controls not related to Russia’s invasion of Ukraine.

Background: Financial institutions are encouraged to continue to use the key term “FIN-2022-RUSSIABIS” when filing SARs related to suspected Russian export control evasion.