FinCEN recently released an alert to all financial institutions, casinos, real estate agents, precious metals/jewellery, and insurance firms regarding potential investments into the U.S commercial real estate sector by sanctioned Russian elites, oligarchs, their proxies, and family members.

The alert lists:

  • Potential red flags and typologies related to attempted sanctions evasion in the commercial real estate sector,
  • Reminds financial institutions of their Bank Secrecy Act (“BSA”) reporting obligations.

Relevant firms should review the notice to ensure appropriate arrangements, controls, and policies are in place to ensure alignment with the alert.

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