FinCEN analysis of Russian oligarchs’ funds flows highlights value of data from financial institutions

Russian oligarchs are increasingly purchasing high-value goods or property as they reroute their finances in response to their country’s invasion of Ukraine and the subsequent slew of international sanctions imposed on them, according to new analysis from the US treasury department’s Financial Crimes Enforcement Network (FinCEN).

Trends in Bank Secrecy Act Data: Financial Activity by Russian Oligarchs in 2022 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. It also highlights the value of BSA data filed by regulated financial institutions.

Blocked and frozen assets

FinCEN and BSA reporting contribute to the multilateral Russian Elites, Proxies, and Oligarchs (REPO) Task Force, which has so far blocked or frozen more than US$30 billion worth of sanctioned Russians’ assets or seized sanctioned persons’ high-value goods, and heavily restrict sanctioned Russians’ access to the international financial system.

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.

Art and jewellery trade

One of the trends identified in FinCEN’s analysis is Russian oligarchs purchasing high-value goods or property, including jewellery, art, and property or real estate in other countries, especially in the lead up to Russia’s invasion of Ukraine.

Russian oligarchs also moved or transferred funds and assets around the time of the Russian invasion of Ukraine in February 2022. Several of them transferred beneficial ownership of their companies, trusts, or accounts to their children, other family members, or close business associates

Rerouting financial flows

BSA data meanwhile indicated potential changes in longstanding oligarch-linked financial flows related to US properties and companies.

Several oligarchs moved funds from accounts in Russia to accounts in other countries, including the US, soon before or around the time of the Russian invasion, and used the funds for property-related expenses.

FinCEN’s Trends in Bank Secrecy Act Data: Financial Activity by Russian Oligarchs in 2022 can be downloaded from here.



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