New FinCEN Analysis of BSA Data Reveals Trends on the Financial … – FinCEN

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:
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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