FinCEN's Latest Russian Sanctions Red Flags

On March 7th 2022, US Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an alert on red flags associated with Russian sanctions evasion. This focus is on the possibility of Russia and Belarus attempting to evade newly sanctions in connection with the Russian Federation’s further invasion of Ukraine alerting financial institutions to be vigilant against efforts to evade the expansive sanctions and other U.S. imposed restrictions implemented. This alert highlights red flags to assist in identifying potential sanctions evasion activity and reminds financial institutions of their Bank Secrecy Act (BSA) reporting obligations, including cryptocurrency businesses to remain on one's guard.



Cryptocurrency Businesses


FinCEN signals Crypto-asset Businesses , generally considered money services businesses (MSB) under the BSA of their compliance obligations to identify and report suspicious activity in relation to potential sanctions. There is a high risk that Money Service Businesses (MSB) customers could evade the new sanctions considering Russia’s strong use and adoption of cryptocurrency. Russian designated individuals and entities could potentially circumvent sanctions imposed.


Sanctions Evasion


"Anti-money laundering/countering the financing of terrorism/counter proliferation (AML/CFT/ CP) and sanctions compliance obligations apply to CVC transactions, just as they do to transactions involving fiat currency. While large scale sanctions evasion using CVC by a government such as the Russian Federation is not necessarily practicable, sanctioned persons, illicit actors, and their related networks or facilitators may attempt to use CVC and anonymizing tools to evade U.S. sanctions and protect their assets around the globe, including in the United States. CVC exchangers and administrators and other financial institutions may observe attempted or completed transactions tied to CVC wallets or other CVC activity associated with sanctioned Russian, Belarusian, and other affiliated persons. (1)"


Some Red Flag Indicators (2)

  • Customer transactions connected to crypto addresses on the OFAC SDN/Blocked Persons List

  • Customer transactions initiated from/made to the following types of Internet Protocol (IP) addresses: non-trusted sources; locations in Russia, Belarus, FATF-identified jurisdictions with AML/CFT/CP deficiencies, and comprehensively sanctioned jurisdictions; or IP addresses previously flagged as suspicious.

  • A customer uses a CVC exchanger or foreign-located MSB in a high-risk jurisdiction with AML/CFT/CP deficiencies, particularly for CVC entities and activities, including inadequate “know-your-customer” or customer due diligence measures.

  • A customer initiates a transfer of funds involving a CVC mixing service.

  • A customer receives CVC from an external wallet, and immediately initiates multiple, rapid trades among multiple CVCs with no apparent related purpose, followed by a transaction off the platform. This may be indicative of attempts to break the chain of custody on the respective blockchains or further obfuscate the transaction.

  • A customer has either direct or indirect receiving transaction exposure identified by blockchain tracing software as related to ransomware.


Need help with Compliance?


Having the right AML Controls (e.g. customer identification, sanction screening, transaction monitoring), technology and expertise from established professionals can help you successfully design and implement an AML Sanctions program scaled to fit you FinTech | Digital Assets model, including a detailed review of the business and prepare effectively a compliance roadmap and culture.


Here at UGR, we will help you navigate with success regulations, compliance and AML/KYC requirements needed in your growth journey. We have some of the finest industry experts covering multiple jurisdictions and work with the best digital asset compliance solutions in the industry to meet all your requirements. Our Compliance As a Service (CaaS) allows you to plan, prioritize, and execute against strategic compliance projects and technology initiatives while matching your budget and pay as you need.


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(1) and (2) FinCEN Alert, FIN-2022-Alert001, March 7, 2022


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