DPMS-SE-001Critical Risk
sanctions evasion
Red Flag
Business customer purchases large volumes of gold using funds wired from a sanctioned jurisdiction, then requests the metals be held in a third-party vault and used as collateral for a letter of credit in a non-sanctioned country.
Industry
Dealers in Precious Metals
Transaction Type
wire
Customer Type
business entity
Category
Regulatory Source
Document:FIN-2022-RUSSIABIS Export Evasion
Type:FinCEN Advisory
CFR Citation:31 CFR §501
SAR Category:Sanctions evasion
FinCEN Key Term:Gold-as-Collateral
Last Verified:2026-04-15
This red flag is provided for informational and educational purposes only. It is not legal, regulatory, or compliance advice. Always consult the official source document and a qualified compliance professional for guidance specific to your situation.