FinCEN has published this analysis which describes financial intelligence about the movement of Russian oligarch-related funds and assets with a nexus to the US around the time of Russia’s unprovoked military invasion of Ukraine, including likely attempts by Russian oligarchs and elites to conceal their assets, property, and financial activities. It provides pattern and trend information contained in Bank Secrecy Act (BSA) reporting filed between March 2022 and October 2022 involving Russian oligarchs, high-ranking officials, and sanctioned individuals.  BSA data in 2022 showed transactional patterns indicative of corruption and sanctions evasion, including the movement or transfer of funds or ownership of assets and trusts; the purchase of high-value goods or property; and changes in financial flows with links to property or companies in the US.  The Acting Director of FinCEN says that the sanctions targets tend to be extremely sophisticated at money laundering and illicit finance, and the US Government will continue to leverage BSA reporting to investigate and counter their illicit networks; and that this financial trend analysis is just another reminder of the critical role that financial institutions play in helping protect the US financial system from illicit activities.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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