U.S. financial institutions should look for sanctionable cyber asset transfers from Russia, FinCEN says

U.S. banks and other financial institutions are being urged by U.S. regulatory agencies to be on the lookout for red flags of transactions by parties seeking to circumvent U.S. sanctions imposed on Russian and Belarusian entities in response to the invasion of Ukraine.  The Financial Crimes Enforcement Network (FinCEN) issued a red flag alert advisory.

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Practical Guidance Updates
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• OFAC Violation Response Checklist and Bank Secrecy Act (BSA), USA PATRIOT Act, AMLA, OFAC, and Other Anti-money Laundering / Anti-terrorism Regulations Compliance Checklist outline the steps and compliance requirements that financial institutions and their counsel must be aware of when responding to an OFAC violation, including those related to recent Russian sanctions.
• A new Ukraine Invasion Resource Kit is available. This tool provides up to date resources to aid financial services institutions navigate through the myriad of Russian sanctions associated with this war. The Compliance with OFAC, AML, and USA Patriot Act Resource Kit is an oversight tool developed to cover key AML and sanctions issues, laws, and regulations applicable to in-house lawyers and counsel advising banking and financial institutions, finance companies, fintech firms, and lenders.
• The Practical Guidance Journal Spring 2022 Edition features guidance for employers on COVID-19 vaccination, testing, and employee health data protection; climate change disclosure market trends; and updates related to the Secured Overnight Financing Rate (SOFR).
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