Regulatory Alerts2023-01-25 | FIN-2023-Alert002Added
FinCEN Alert on Potential U.S. Commercial Real Estate Investments by Sanctioned Russian Elites, Oligarchs, and Their Proxies
FinCEN alerts financial institutions to potential sanctions evasion by sanctioned Russian elites and their proxies through U.S. commercial real estate investments, highlighting vulnerabilities such as opaque ownership structures and the use of pooled investment vehicles. The alert provides specific typologies and red flags, including the use of offshore entities, shell companies, trusts, and third parties to conceal beneficial ownership below standard Customer Due Diligence thresholds. Financial institutions are requested to reference the alert in Suspicious Activity Report filings by including the key term "FIN-2023-RUSSIACRE" in the filing note and narrative.