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FinCEN Raises Sanctions Warning Over US Commercial Real Estate

Banks, insurance companies and other financial institutions in the U.S. should be on guard for attempts by “Russian elites and their proxies” to invest in commercial properties, the Financial Crimes Enforcement Network warned Wednesday.

Among other red flags, bids by offshore private investment vehicles to purchase commercial properties and any reluctance to provide beneficial ownership information may indicate efforts to evade U.S. sanctions against Russia, as may the use of multiple corporate entities or trusts during a commercial real estate transaction, the bureau noted in an 11-page advisory.

“According to one study of 2021 U.S. CRE [commercial real estate] transactions, 8.4 percent of those surveyed reported that they closed a sale with a foreign client residing abroad, and this figure was above 10 percent for several years prior to the pandemic,” FinCEN noted in the advisory, which lists nine red flags altogether.

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Topics : Anti-money laundering
Source: U.S.: FinCEN
Document Date: January 25, 2023