Purchases under letters of credit (L/Cs) that are consigned to the issuing bank are amongst several red flags listed in new suspicious activity reporting (SAR) guidance to support US financial institutions in reporting potential efforts to evade US export controls.

The guidance issued jointly by the US Bureau of Industry and Security and the Financial Crimes Enforcement Network (FinCEN) also introduces a new SAR key term, ‘FIN-2023-GLOBALEXPORT’, which US financial institutions should reference when reporting suspicious activity to FinCEN.

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