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Banks Report U.S. $1BN of Suspected Russian Export Control Evasion

Global Trade Review

Banks have detected almost US$1bn worth of transactions suspected to have facilitated exports from the US to Russia in possible violation of sanctions, the US financial crime enforcement agency says.

Since Russia’s February 2022 invasion of Ukraine, US exporters of sensitive goods have received payments directly from Russia or through intermediary companies in other countries in transactions that could contravene US export controls, an analysis of reports filed by banks under the Banking Secrecy Act shows.

The findings, published by the Financial Crimes Enforcement Network (FinCEN) on September 8, further confirm that since the outbreak of the war Russian importers have been able to circumvent export controls and other sanctions by routing trade with Western economies through a handful of third countries.


Overall, the 333 reports made by banks scrutinised by FinCEN for its analysis detailed almost US$1bn in suspicious activity. The figure “seems like a high amount for illicit diversion in the export control context,” says Anthony Rapa, co-chair of law firm Blank Rome’s international trade practice, noting that it only represents what has been detected.

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"Banks Report U.S. $1BN of Suspected Russian Export Control Evasion," by Jacob Atkins was published in Global Trade Review on September 13, 2023.