Suspicious Activity Reports Helping Export Probes, Entity List Proposals, BIS Official Says

The Bureau of Industry and Security has reviewed more than 1,250 suspicious activity reports (SARs) submitted to the government as part of an effort with the Treasury Department to collect more tips from industry about possible Russia-related sanctions or export control violations, said Matthew Axelrod, the top BIS export enforcement official.

Of those 1,250 reports, Axelrod said about 13% have either contributed to new leads to BIS enforcement agents for new or existing export investigations, or have helped the agency refer parties for possible inclusion on the Entity List.

“For those of you who know SARs and how often SARs get actioned,” that’s a “very high percentage,” he said during an event last week hosted by the Atlantic Council. “We're looking at them all, but” 13% of the reports have been “useful in actually actively aiding our investigative and enforcement efforts.”

Axelrod in January said BIS had received over 500 SARs as part of the effort with the Treasury Department’s Financial Crimes Enforcement Network (see 2401170059). The two agencies last year released two codes for banks to include in their SARs. which signal to FinCEN that their report involves a suspected violation of sanctions or export controls (see 2311060055, 2212160027, 2207130014 and 2309110049).