This guidance outlines steps FIs can take to reduce the risk of EAR violations. Key recommendations include implementing due diligence best practices, conducting ongoing transaction reviews for red flags, and clarifying which real-time transaction screenings are considered best practice.
To prevent violations of GP 10 of the EAR, the guidance emphasizes screening customers during onboarding and periodically thereafter against the U.S. Consolidated Screening List, which includes entries from BIS, the Office of Foreign Assets Control (OFAC), and the Directorate of Defense Trade Controls (DDTC).
In line with previous joint notices from BIS and the Financial Crimes Enforcement Network (FinCEN), FIs are expected to report suspicious activities related to potential EAR violations and to use relevant key terms in Suspicious Activity Reports (SARs).
Additionally, the guidance highlights ongoing sanctions related to Russia.