Given the critical impasse you are at and the immediate demand for BSA compliance caused by the horrific war in Ukraine, we have moved your inquiry to the top of the FAQ list. I will provide a response that should help you procedurally. The Financial Crimes Enforcement Network (FinCEN) closely monitors SARs filed in response to the sanctions relating to Russia and Belarus (and other affiliated persons).
If you are unsure of the filing requirements and need information, I suggest that you contact FinCEN’s Regulatory Support Section at frc@fincen.gov. If you need to expedite the filing, you should call FinCEN’s toll-free hotline at (866) 556-3974 (continuously monitored). Keep in mind that you should immediately report any imminent threat to law enforcement officials in your region.
It is helpful that you contacted and shared your concerns with financial institutions in your area. Information sharing among financial institutions is critical to identifying, reporting, and preventing evolving sanctions evasion, ransomware and cyber attacks, and laundering of the proceeds of corruption.
Financial institutions and associations of financial institutions sharing information under the safe harbor authorized by section 314(b) of the USA Patriot Act may share information with one another regarding individuals, entities, organizations, and countries suspected of possible terrorist financing or money laundering. Indeed, FinCEN strongly encourages such voluntary information sharing.
Evading sanctions is nothing new for crooks. However, due to the Russian and Belarusian actions, sanctioned Russian and Belarusian actors may seek to evade sanctions through various means, such as by moving transactions through non-sanctioned Russian and Belarusian financial institutions and financial institutions in third countries. Red Flags should be taken as one of the tools to identify such transactions, but you will also need to add to the list as incidents require.
