In reviewing Bank Secrecy Act filings, the Financial Crimes Enforcement Network of the U.S. Department of Treasury identified up to a $1 billion worth of transactions that could have evaded Russia-related export controls and sanctions between 2016 and 2022. Financial institutions that submitted the Bank Secrecy Act reports flagged the transactions as being suspicious based on its review of the transaction information, bills of lading, invoices, and additional research conducted.
