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



On December 22, 2022, The Financial Crimes Enforcement Network (FinCEN) issued a Financial Trend Analysis on the financial activity of Russian oligarchs. 

The research focuses on patterns observed in Bank Secrecy Act (BSA) reports involving Russian billionaires, senior officials, and sanctioned people that were submitted between March 2022 and October 2022. The importance of BSA data submitted by regulated financial institutions is also highlighted in the study.

According to the report, FinCEN uncovered 454 BSA reports describing tens of billions of dollars’ worth of questionable behavior after reviewing BSA reports filed on Russian billionaires, senior officials, and sanctioned persons. The following are a few data trends:

  • 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.

In addition to reminding financial institutions of their BSA reporting duties, including with regard to convertible virtual currency, these alerts include specific red flags to help identify suspected sanctions evasion behavior.

You can read the full report here: FinCEN Report



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Adnan is a published author and has been working in the financial crime industry for over 10 years. He is the founder of ComplyChain Solutions, BitDollars and CoinForensics. Visit his LinkedIn page to learn more.

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