The Financial Crimes Enforcement Network recently issued an alert cautioning all financial institutions about potential investments in the U.S. commercial real estate sector, by or on behalf of Russian elites and their proxies. FinCEN’s communication complements U.S. efforts, in response to Russia’s war against Ukraine, to isolate sanctioned Russian persons from the international financial system. In addition to highlighting specific vulnerabilities to sanctions evasion in this sector, the alert provides guidance to help financial institutions identify red flags for such activities.

Read on for details about the alert and recommended next steps for financial institutions.