Suspicious activity reporting
Suspicious activity reporting in Trade and Geopolitical Risk sits at the intersection of two enforcement regimes that rarely coordinate: the Financial Crimes Enforcement Network's SAR obligations under the Bank Secrecy Act and the Office of Foreign Assets Control's sanctions-related reporting expectations, both of which apply to firms with cross-border trade exposure. The U.S. Department of Commerce Bureau of Industry and Security has also signaled, through its 2023 antiboycott and export enforcement guidance, that voluntary self-disclosure patterns are being scrutinized alongside SAR filing behavior. Compliance teams are currently pressure-testing whether their dual-use goods workflows trigger SAR thresholds before a transaction clears, not after.
Watch
- FinCEN's beneficial ownership SAR intersection with shell-company trade financing
- BIS voluntary self-disclosure policy: revised timelines and penalty mitigation criteria
- OFAC's 50 Percent Rule applied to sanctioned-country counterparties in supply chains
- SAR filing thresholds when trade finance instruments route through non-FATF jurisdictions
Recent material activity in Trade & Geopolitical Risk
ITC lifts partial suspension of exclusion and cease-and-desist orders covering photodynamic therapy systems under Sun Pharma patent
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Read a full sample brief →USITC adds AnaBio Technologies Unlimited Company as respondent in coated confectionery Section 337 investigation
The U.S. International Trade Commission declined to review an administrative law judge's initial determination on September 4, 2026, granting an unopposed motion to amend the complaint in an active Section 337 investigat…
Read a full sample brief →HMRC updates CDS BIRDS and CCR completion instructions to accept EU EORI numbers from 4 July 2026
HMRC updated the Customs Declaration Service BIRDS and Customs Clearance Request completion instructions on 4 September 2026. The revision accepts EU-country EORI numbers in specified data elements from 4 July 2026 and p…
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HMRC published an updated Data Element Completion Guide on September 4, 2026 for Customs Declaration Service Customs Clearance Requests covering inventory exports only. The update reflects the creation of the Department …
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Read a full sample brief →HMRC updates CDS Appendix 5C licence-type code tables with three new document codes effective September 2026
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Read a full sample brief →Dutch Customs activates Digital Dossier for DECO declarations on 19 September 2026
Dutch Customs published a notice on 4 September 2026 announcing that the Digital Dossier system will become available for DECO declarations on 19 September 2026. From that date, declarants must submit supporting document…
Read a full sample brief →CBIC mandates structured customs checklists for cosmetics, drugs, and medical devices at PGA-facilitated import clearance
India's Central Board of Indirect Taxes and Customs issued Circular 40/2026 on September 3, 2026, requiring customs officers to complete mandatory compliance checklists before granting out-of-charge on Partner Government…
Read a full sample brief →India CBIC amends EMI Scheme documentation requirements, rationalizing importer compliance obligations under customs circular
India's Central Board of Indirect Taxes and Customs issued Circular 39/2026-Customs on September 3, 2026, amending the documentation framework for the Eligible Manufacturer Importer Scheme established in February 2026. T…
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