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U.S. actions to Russia-Ukraine war: FinCEN Alert

“Red flag” indicators of potential efforts to circumvent sanctions

Financial services companies are facing rapid and iterative regulatory expectations around current and expected OFAC sanctions and Administration executive orders. Regulators will expect companies to apply tight controls around areas of currently heightened risk given the Russian government’s ongoing attack on Ukraine, including sanctions compliance, financial crimes, cyber security, and crypto and digital assets. FinCEN’s Alert focuses attention to key BSA/AML/CTF areas such as beneficial ownership, crypto and digital asset transactions, ransomware attacks and payments, and customer due diligence.

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U.S. actions to Russia-Ukraine war: FinCEN Alert

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Amy S. Matsuo
Principal, U.S. Regulatory Insights & Compliance Transformation Lead, KPMG LLP

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