On December 22, 2022, FinCEN issued a Financial Trend Analysis on the financial activity of Russian oligarchs. The report focuses on trends seen in Bank Secrecy Act (BSA) reports filed involving Russian oligarchs, high-ranking officials, and sanctioned individuals. In addition, the report highlights the value of BSA data filed by regulated financial institutions.

FinCEN examined BSA reports from March 2022 to October 2022 filed on Russian oligarchs, high-ranking officials, and sanctioned individuals. The agency found 454 BSA reports detailing tens of billions of dollars in suspicious activity. FinCEN identified trends from their analysis including the following:

Russian oligarchs moved or transferred funds and assets to their children, other family members, or close business associates around the time of the Russian invasion of Ukraine in February 2022;
Russian oligarchs purchased high-value goods or property in 2022 leading up to the invasion; and
BSA data indicated potential changes in longstanding oligarch-linked financial flows related to U.S. properties and companies.

Read FinCEN’s full news release here.

The Financial Trend Analysis can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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