INV-SE-001Critical Risk
sanctions evasion
Red Flag
Foreign national uses a U.S.-domiciled investment fund to hold assets that are effectively controlled by a sanctioned individual, with the nominee structure designed to avoid OFAC screening.
Industry
Investment Advisers
Transaction Type
wire
Customer Type
foreign national
Category
Regulatory Source
Document:FIN-2022-RUSSIABIS Export Evasion
Type:FinCEN Advisory
CFR Citation:31 CFR §501
SAR Category:Sanctions evasion
FinCEN Key Term:Nominee Fund Structure
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.