FinCEN Alert on Real Estate, Luxury Goods, and Other High Value Assets Involving Russian Elites, Oligarchs, and their Family Members (FIN-2022-Alert002)

FIN-2022-Alert002 March 16, 2022
FinCEN Alert on Real Estate, Luxury Goods, and Other High￾Value Assets Involving Russian Elites, Oligarchs, and their Family Members

1. See FinCEN’s first Alert, “FinCEN Advises Increased Vigilance for Potential Russian Sanctions Evasion Attempts,”
   (March 7, 2022) for additional information regarding potential Russian and Belarusian sanctions evasion.
2. See 31 U.S.C. § 5318(g); 31 CFR §§ 1020.320, 1021.320, 1022.320, 1023.320, 1024.320, 1025.320, 1026.320, 1029.320, and
   1030.320.
3. Luxury goods can include high-end watches, luxury vehicles, yachts and planes, high-end apparel, high-end alcohol,
   jewelry, and other goods frequently purchased by Russian elites. See White House Fact Sheet, “FACT SHEET: United States, European Union, and G7 to Announce Further Economic Costs on Russia,” (March 11, 2022). Other high￾value assets can include physical works of art, precious stones (such as diamonds) and metals (such as gold) among other similar items. See U.S. Department of the Treasury (Treasury), “National Money Laundering Risk Assessment,” (February 2022), at pp. 58-63.
4. The red flags highlighted in this alert are derived from FinCEN’s analysis of Bank Secrecy Act (BSA) reporting or
   publicly cited sources, and represent only a sampling of indicators of possible sanctions evasion or other illicit activity and should not be considered an exhaustive list. Further, because no single financial red flag is determinative of illicit or suspicious activity, financial institutions should consider the relevant facts and circumstances of each transaction, in keeping with their risk-based approach to compliance.
5. See 31 U.S.C. § 5312(a)(2); 31 CFR § 1010.100(t).
6. See White House “Joint Statement by the G7 Announcing Further Economic Costs on Russia,” (March 11, 2022).
   See also U.S. Department of Justice Press Release, “Attorney General Merrick B. Garland Announces Launch of Task Force KleptoCapture,” (March 2, 2022). The Financial Crimes Enforcement Network (FinCEN) is issuing a second1 alert on the importance of identifying and quickly reporting suspicious transactions2 involving real estate, luxury goods, and other high-value assets of sanctioned Russian elites and their family members and those through which they act (collectively, “sanctioned Russian elites and their proxies”).3 This alert provides select red flags4 to assist financial institutions5 in identifying suspicious transactions, and reminds financial institutions of their Bank Secrecy Act (BSA) reporting obligations. This alert also complements other recent coordinated U.S. Government actions related to luxury goods, and highlights the establishment of U.S. and international task forces and programs designed to freeze and seize the assets of sanctioned Russian actors.6 Because real estate, luxury goods, and other high-value assets can be used as a store of value, a medium of exchange, or an investment, sanctioned Russian elites and their proxies may use such assets to evade expansive U.S. and other sanctions and restrictions imposed in response to the Suspicious Activity Report (SAR) filing request:
   FinCEN requests financial institutions reference this alert in SAR field 2 (Filing Institution Note to FinCEN) and the narrative by including the following key term:
   “FIN-2022-RUSSIALUXURY”