FinCEN notes BSA reporting on Russian oligarchs since invasion of Ukraine

Bank Secrecy Act (BSA) reports filed on Russian oligarchs, high-ranking officials, and sanctioned officials over an eight-month period included 454 reports detailing “tens of billions of dollars in suspicious activity” since Russia’s Feb. 24 invasion of Ukraine, Treasury’s financial crimes enforcement unit said Thursday.

The Financial Crimes Enforcement Network (FinCEN) notes summary findings in a Financial Trend Analysis (FTA) that focuses on BSA reports filed from March 1 through Oct. 31 of this year.

FinCEN, in its analysis, said it reviewed approximately 7,000 reports during the period that had a nexus to Russia, and 454 of those detailed transactions linked to Russian oligarchs, high-ranking officials, and sanctioned individuals. It said the FTA report also highlights the value of BSA data filed by regulated financial institutions.

It said U.S.-based depository institutions filed the majority, or 78%, of the 454 reports analyzed. It said other types of financial institutions, including holding companies or financial technology companies, submitted roughly 19% of these reports (mostly reporting suspicious electronic funds transfers or wire transfers and suspicions concerning the source of funds). Also, it said, filers in 284 of the BSA reports referred to previous Russia-related alerts issued by FinCEN.

FinCEN said the data referred to in the FTA showed, among other things, that:

  • 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.

The financial crimes unit also drew attention to the multilateral Russian Elites, Proxies, and Oligarchs (REPO) Task Force, led jointly by Treasury and the Justice Department. It said FinCEN and reporting under the BSA contribute to the work of this body, which “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.”

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

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