FinCEN Guidance on Transactions by Sanctioned Russian Elites

3 mins

The Financial Crimes Enforcement Network (FinCEN) of the United States Treasury issued a warning to financial institutions about how Russian elites who are subject to sanctions might try to get around them, pointing out red flags that could help identify potentially suspicious transactions by them or their families.

The Treasury Department also unveiled the launch of the Kleptocracy Asset Recovery Rewards Programme, which offers rewards of up to US$5 million for information that would lead to the government obtaining or repatriating stolen assets in the accounts of a U.S. financial institution.

FinCEN noted that one way Russian elites would try to avoid sanctions is to buy commercial or luxury real estate and that transactions conducted in the name of a foreign legal organisation could be a red flag, especially if the acquisition was considerably above fair market value or all cash.

Other high-value assets, such as artworks, luxury yachts and vehicles, and precious metals, stones, or jewellery, might be used to escape sanctions, according to FinCEN, which warned against all-cash transactions or the use of shell companies in these sectors.

The treasury also announced that the Kleptocracy Asset Recovery Rewards Programme will be used to “identify, confiscate, and recover the assets of kleptocrats and other corrupt persons,” with an emphasis on those tied to the Russian government.

The warning was issued when the Russian Elites, Proxies, and Oligarchs (REPO) task force met for the first time, with the purpose of seizing the assets of Russian President Vladimir Putin’s political and commercial supporters.


Tookitaki’s Sanctions Screening Solutions

When doing business with customers from Russia or with ties to Russia, businesses must ensure that they are not breaking international sanctions. They need to ensure they are in compliance with guidelines provided by regulators including the US FinCEN.

Explore our Smart Screening solution, powered by real-time screening and cutting-edge machine learning technology to enable efficient, accurate, risk-based sanctions checks against Russia.


Name Matching Like No Other

Our powerful name matching engine screens and prioritises all name search hits, ensuring efficiency in the investigation process and reducing the cost of compliance.

This entails putting in place a suitable sanctions screening solution that is kept up to date with the most recent sanctions data and supports the Russian language via translation and transliteration.

The specific challenges of screening potential Russian sanctions targets, such as non-Western naming conventions, non-Latinate characters, and the use of nicknames and aliases, should all be taken into account for effective sanctions screening.

  • It enables you to achieve 80% precision and 90% recall levels in your screening programme
  • Advanced machine learning engine that powers 50+ name matching techniques
  • Comprehensive matching is enabled by the use of multiple attributes i.e; name, address, gender, date of birth, incorporation and more
  • Individual language models to improve accuracy across 18+ languages (including Russian) and 10 different scripts
  • Built-in transliteration engine for effective cross-lingual matching
  • Scalable to support massive watchlist data

Screen Transactions In Real-Time

Our state-of-the-art screening architecture provides faster and more accurate matching that reduces held transactions. Our system automatically screens your existing customer base against any changes or additions to watchlists in real-time. They’ll be detected and flagged with zero human intervention, leaving your team to concentrate on other issues.

  • Real-time screening of parties involved in the transaction against sanctions lists of your choosing
  • Near matching capabilities powered by advanced machine learning produce highly accurate screening results, ensuring that legitimate payments are not delayed


Drive Operational Efficiency

Our self-adaptive system significantly reduces false positives, this allows you to focus on material risk.

  • Using an AI-powered risk-based strategy, alerts are automatically triaged into three risk categories
  • 85% – 90% of low-value alerts can be closed through fast alert disposition
  • 60%+ reduction in false positives in comparison to legacy systems

Speak to a member of the team to learn more and ensure you’re not breaching international sanctions.