Trends in Bank Secrecy Act Data: Financial Activity by Russian Oligarchs in 2022

i

Trends in Bank Secrecy Act Data: Financial Activity by Russian Oligarchs in 2022 This Financial Trend Analysis (FTA) describes financial intelligence about the movement of Russian oligarch-related funds and assets with a nexus to the United States 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.1 These reports detailed tens of billions of dollars in suspicious activity. FinCEN highlighted red flags on Russian oligarchs, high￾ranking officials, and sanctioned individuals in three Alerts since Russia’s unprovoked military invasion of Ukraine: FinCEN Advises Increased Vigilance for Potential Russian Sanctions Evasion Attempts (Alert FIN-2022-Alert001 on 7 March 2022); FinCEN Alert on Real Estate, Luxury Goods, and Other High Value Assets Involving Russian Elites, Oligarchs, and their Family Members (Alert FIN-2022-Alert002 on 16 March 2022); and FinCEN and the U.S. Department of Commerce’s Bureau of Industry and Security Urge Increased Vigilance for Potential Russian and Belarusian Export Control Evasion Attempts (Alert FIN-2022-Alert003 on 28 June 2022). These Alerts build on the national priorities for anti-money laundering and countering the financing of terrorism that FinCEN issued on 30 June 2021, which included corruption and transnational criminal organization activity. Executive Summary: In response to Russia’s unprovoked military invasion of Ukraine on 24 February 2022, FinCEN implemented multiple lines of effort to analyze and share financial intelligence with the public, law enforcement agencies, and other relevant stakeholders.2 FinCEN undertook these efforts to support U.S. government efforts to track, freeze, and seize assets of Russian oligarchs, high-ranking officials, and sanctioned individuals. The funds underlying many of these financial transactions may represent proceeds of corruption or involve the property or interests in property of persons blocked by the Treasury Department’s Office of Foreign Assets Control (OFAC) pursuant to U.S. economic sanctions programs and regulations. BSA data filed on financial transactions of Russian oligarchs, high-ranking officials, sanctioned individuals, and their family members 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 United States.

1. This report is issued pursuant to section 6206 of the Anti-Money Laundering Act of 2020 (AMLA), which requires
   the Financial Crimes Enforcement Network (FinCEN) to periodically publish threat pattern and trend information derived from BSA filings. The AMLA was enacted as Division F, §§ 6001-6511, of the William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021, Pub. L. 116-283 (2021).
2. Since March 2022, FinCEN has also published several alerts urging U.S. financial institutions to be vigilant against
   efforts to evade the expansive sanctions and other U.S.-imposed restrictions implemented in connection with Russia’s unprovoked military invasion of Ukraine. These alerts provide select red flags to assist in identifying potential sanctions evasion activity and reminds financial institutions of their BSA reporting obligations, including with respect to convertible virtual currency.