New FinCEN Analysis of BSA Data Reveals Trends on the Financial Activity of Russian Oligarchs

December 22, 2022

WASHINGTON—The Financial Crimes Enforcement Network (FinCEN) issued a Financial Trend Analysis today on the financial activity of Russian oligarchs. The report focuses on trends seen in Bank Secrecy Act (BSA) reports filed between March 2022 and October 2022 involving Russian oligarchs, high-ranking officials, and sanctioned individuals. The report also highlights the value of BSA data filed by regulated financial institutions.

FinCEN and BSA reporting contribute to the multilateral Russian Elites, Proxies, and Oligarchs (REPO) Task Force, led jointly by the Departments of the Treasury and Justice. The REPO Task Force has leveraged extensive multilateral coordination to block or freeze more than $30 billion worth of sanctioned Russians’ assets, freeze, or seize sanctioned persons’ high-value goods, and heavily restrict sanctioned Russians’ access to the international financial system.

“BSA reporting provides substantial support for U.S. government efforts to track, freeze and seize assets of Russian oligarchs, elites, and their proxies,” said FinCEN Acting Director Himamauli Das. “These targets tend to be extremely sophisticated at money laundering and illicit finance, and the U.S. government will continue to leverage BSA reporting to investigate and counter their illicit networks. This financial trend analysis is just another reminder of the critical role that financial institutions play in helping protect the U.S. financial system from illicit activities.”

FinCEN examined BSA reports filed on Russian oligarchs, high-ranking officials, and sanctioned individuals, and identified 454 BSA reports detailing tens of billions of dollars in suspicious activity. Some of the trends in the data include:

• Russian oligarchs moved or transferred funds and assets around the time of the Russian invasion of Ukraine in February 2022—Several Russian oligarchs transferred beneficial ownership of their companies, trusts, or accounts to their children, other family members, or close business associates
• Russian oligarchs purchased high-value goods or property in 2022—This included jewelry, art, and property or real estate in other countries leading up to the invasion.
• BSA data indicated potential changes in longstanding oligarch-linked financial flows related to U.S. properties and companies—Several oligarchs moved funds from accounts in Russia to accounts in other countries, including the United States, soon before or around the time of the Russian invasion, and used the funds for property-related expenses.

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 remind financial institutions of their BSA reporting obligations, including with respect to convertible virtual currency. Financial institution filers noted these Russia-related alerts in 284 of the 454 BSA reports analyzed for this Financial Trend Analysis.

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