The Russian Elites, Proxies, and Oligarchs (REPO) Task Force has released a statement on the progress and impact of its efforts to block and freeze assets and to restrict access to the international financial system by sanctioned persons since the inception of the Russian war in Ukraine. The report emphasizes national and international coordination, collaboration, and information sharing, including incorporating information gathered from law enforcement, joint investigations, financial intelligence and the private sector among REPO members (Australia, Canada, France, Germany, Italy, Japan, the United Kingdom, the United States, and the European Commission).
Among the REPO Task Force’s successes thus far are the blocking of over $58 billion worth of assets, and the seizure or freezing of billions of dollars of luxury assets such as yachts and real estate, immobilization of many of the assets of the Russian Central Bank and the Russian National Wealth fund, obtained the forfeiture of assets belonging to a sanctioned Russian, and the transfer of $5.4 million in foreign assistance to Ukraine, widespread enforcement efforts among REPO members, and updating of several REPO members’ legal frameworks to enable enforcement.
The REPO Task Force’s statement describes five typologies of Russian sanctions evasion tactics, and recommends approaches to prevent sanctions evasion, and to advance the goal of depriving Russia of the funds it needs to fight the war against Ukraine. The five typologies are:
- Use of family members and close associates to retain access to and control of assets;
- Use of real estate as a vehicle to maintain wealth;
- Use of complex ownership structures to evade detection and identification;
- Use of enablers such as lawyers, accountants, trust and company service providers, to open bank accounts, send and receive money, and consolidate investments for groups of individuals, and;
- Use of third-party jurisdictions and false shipping information to facilitate the transfer of goods to Russia.
In order to prevent the use of these sanctions evasions tactics, the REPO Task Force recommends that regulated entities — both financial institutions and other businesses – follow the recommendations of the financial action Task force, and take all necessary measures to comply with anti-money laundering and anti-terrorism financing laws in their jurisdictions. In addition, the Task Force recommends that regulated entities engage with public and private partners, and leverage information sharing protocols to the extent it is feasible to do so. The Task Force further recommends that entities update their risk assessments to take into account current circumstances globally and new techniques being used to evade sanctions. Finally, the Task force advises that efforts be made to increase awareness among unregulated as well as regulated entities, since both could be exposed to a heightened risk of facilitating sanctions evasion.