On 25 January, FinCEN advised that it had issued an Alert to financial institutions regarding potential investments in the US commercial real estate sector by sanctioned Russian elites, oligarchs, their family members, and the entities through which they act. It lists red flags and typologies involving potential sanctions evasion in the commercial real estate sector. The new Alert builds on that from March 2022t identifying real estate, luxury goods, and other high value assets involving sanctions Russian and elites, is the fourth alert issued by FinCEN on potential Russian illicit financial activity since Russia’s invasion of Ukraine in February 2022.
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