FinCEN Puts $5M Bounty On Assets 'Stolen' By Russian Elites

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” href=””>Al Barbarino Law360 (March 17, 2022, 7:51 PM EDT) — The U.S. Treasury Department warned banks about potential ploys by Russian elites to evade U.S. sanctions through transactions involving real estate, fine art, yachts and other pricey items, concurrently launching a program that could pay more than $5 million to tipsters who help seize such “stolen” assets.

Treasury’s Financial Crimes Enforcement Network noted in the alert Wednesday that Russian elites, family members and their associates could use “high-value” items — including real estate, artwork, precious metals, jewelry, vehicles and yachts — to evade sanctions levied against them in response to the Russian invasion of Ukraine.

The alert lays out dozens of red flags that financial institutions should be on the lookout for and potentially report to the department.

For instance, shell companies are often used to purchase, hold or sell real estate, fine art and other items, FinCEN said, urging banks to peel back the layers of potential transactions made by such entities.

Banks should examine if the transactions appear to be far above or below fair market value, and alarm bells should also go off if a Russian individual or entity requests a wire transfer from a non-U.S. bank to pay for an all-cash purchase of the assets, FinCEN noted.

Real estate may offer an “attractive vehicle for storing wealth or laundering illicit gains”

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