2022-03-16 | FIN-2022-Alert002Added
Financial institutions are advised to identify and report suspicious transactions involving real estate, luxury goods, and other high-value assets linked to sanctioned Russian elites and their proxies to evade sanctions. The alert provides specific red flags for these asset classes, including the use of shell companies, all-cash transfers, and opaque corporate structures, to assist in complying with Bank Secrecy Act reporting obligations. Institutions are requested to reference the alert in Suspicious Activity Report narratives by including the key term "FIN-2022-RUSSIALUXURY".