FinCEN Announces Actions to Support REPO Multilateral Task Force and Ongoing U.S. Government Efforts to Combat Foreign Government Corruption 

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Immediate Release

March 16, 2022

Takes Steps to Increase Information Sharing with Task Force Countries, Enhances Engagement with Financial Institutions, and Issues a New Alert on Russian Oligarchs, Elites, and Their Family Members

WASHINGTON—The Financial Crimes Enforcement Network (FinCEN) is announcing its efforts to support the multilateral Russian Elites, Proxies, and Oligarchs (REPO) Task Force, announced earlier today by the U.S. Department of the Treasury and the U.S. Department of Justice. The task force aims to deny and disrupt illicit actors’ ability to deceptively access the international financial system and conduct economic activity. FinCEN is supporting Treasury’s efforts to boost cooperation and intelligence sharing by agreeing to increase information sharing with relevant authorities in task force member countries. FinCEN is also issuing a FinCEN Alert, which highlights the importance of financial institutions identifying and quickly reporting suspicious transactions by sanctioned Russian elites and their proxies that involve real estate, luxury goods, and high-value assets.

“Financial intelligence is fundamental to U.S. bilateral and multilateral efforts to trace, freeze, and seize the corrupt gains of Russian elites and their enablers,” said FinCEN Acting Director Himamauli Das. “It is critical that financial institutions increase their awareness of indicators of potential Russian sanctions evasion and that governments work together to collect and share information in this rapidly evolving crisis. We appreciate the collaboration of our financial institution and government partners in this effort.”

Today, FinCEN joined the financial intelligence units (FIUs) of Australia, Canada, France, Germany, Italy, Japan, New Zealand, the United Kingdom, and the Netherlands in issuing a statement of intent to form an FIU Working Group on Russia-Related Illicit Finance and Sanctions. The FIUs affirmed the need to identify concrete actions that participating Working Group Members can take individually or collectively to enhance financial intelligence on sanction-related matters; expedite and increase sharing of financial intelligence in sanction-related matters; establish FIU best practices based on lessons learned, and identify opportunities for actions and partnerships to combat the threat caused by Russia’s unprovoked invasion into Ukraine; and strengthen and facilitate working relationships between FIUs and competent public authorities and the private sector addressing that threat, including by engaging with the REPO Task Force.

Also today, FinCEN issued an Alert to financial institutions on the importance of identifying and quickly reporting suspicious transactions involving real estate, luxury goods, and other high-value assets of sanctioned Russian elites and their proxies. The Alert provides select red flags to assist financial institutions in identifying suspicious transactions, and reminds financial institutions of their Bank Secrecy Act reporting obligations. Because real estate, luxury goods, and other high-value assets can be used as a store of value, a medium of exchange, or an investment, Russian elites and their proxies may use such assets to evade expansive U.S. and other sanctions and restrictions imposed in response to their support of Russia’s invasion of Ukraine.

In addition, FinCEN is continuing robust engagement with financial institutions, including through its public-private partnership FinCEN Exchange, to explore typologies and share best practices to enable the private sector to better identify corrupted gains by elites, oligarchs, and their proxies and provide FinCEN and law enforcement with critical information to track, freeze, and seize the assets of Russian elites and their proxies.

RUSSIA-RELATED ILLICIT FINANCE AND SANCTIONS FIU WORKING GROUP STATEMENT OF INTENT

Immediate Release

March 16, 2022

We, the Financial Intelligence Units of Australia, Canada, France, Germany, Italy, Japan, the Netherlands, New Zealand, the United Kingdom, and the United States, referred to herein as Working Group Members issue this statement of intent:

Recalling statements made by governments around the world, including Australia, Canada, France, Germany, Italy, Japan, New Zealand, the United Kingdom, the United States of America, and the High Representative of the European Union, condemning Russia’s unprovoked and unjustifiable war of choice against Ukraine, enabled by the Belarussian government (“the threat”);

Recognizing that the respective governments of the Working Group Members and the European Union have imposed several rounds of far-reaching economic and financial sanctions, and committed to imposing further sanctions in response to the threat;

Further recognizing that the governments of several Working Group Members and the European Commission, consistent with their respective legal frameworks, have agreed to establish an international task force to coordinate efforts related to sanctions and asset recovery;

Underscoring the need for FIUs to cooperate with law enforcement, prosecutors, other competent authorities, and the private sector, within the legal framework of the respective FIUs, to achieve the goals of the international task force and more generally to combat the associated illicit activities including money laundering, sanctions evasion, cyber threats, and corruption;  

Stressing the importance of the role of Financial Intelligence Units in the collection, sharing, analysis, dissemination, and use of financial intelligence to address money laundering and the financing of terrorist activities, and

Recalling that, under the current international, EU and national legal frameworks, FIUs do not have a uniform and comprehensive legal basis and mandate to receive, analyse and share information on financial sanctions and related measures;

Affirm the need to identify concrete actions that participating Working Group Members, within their respective legal framework, can take individually or collectively to

1. Enhance financial intelligence on sanction-related matters and associated financial flows and economic activities;

2. Expedite and increase sharing of financial intelligence in sanction-related matters and associated financial flows and economic activities;

3. Engage in discussions concerning FIU best practices, lessons learned, and opportunities for actions and partnerships to combat the threat; and

4. Strengthen and facilitate working relationships between FIUs and competent public authorities and the private sector addressing the threat, including by engaging with task forces established by governments of the Working Group Members.