Rewards: Any information leading to seizure of Russian Assets

It would almost be hard to keep up with the pace of sanctions & counter sanctions publications pertaining to Russia/Belarus following the invasion of Ukraine in recent weeks. As sanctions and counter-sanctions are still raining as we speak on this March 16, 2022, and will probably have changed by the time I’m done with this blog post, I will wait until things slow down before attempting a recap.

In the meantime, the latest US Treasury announcement caught my attention this evening:

Australia, Canada, the European Commission, Germany, Italy, France, Japan, the UK, and US, Agree to Increased Cooperation to Target Russian Assets.

And just like that REPO was born.

For those who may have missed it under the sea of new announcements, REPO was actually first announced in a joint statement issued by the White House on February 26. REPO is essentially the US, Australia, Canada, Germany, France, Italy, Japan, the United Kingdom, and the European Commission, agreeing to launch a Russian Elites, Proxies, and Oligarchs multilateral task force ( aka REPO).  

The task force which consists of the Finance Ministry and Justice or Home Ministry in each of the above mentioned countries, agrees to use their respective authorities in concert with other appropriate ministries to collect and share information to take concrete actions, including sanctions, asset freezing, and civil and criminal asset seizure, and criminal prosecution.

In plain terms, these countries have joined forces to seize Russian Elites & Oligarchs’ assets.

The REPO task force is also contemplating ways to bring to justice enablers and gatekeepers who are facilitating the movement of sanctioned assets or other illicit funds.

According to the US Treasury, the cooperation has already been a great success, with in the last three weeks alone, the seizure of multiple vessels controlled by sanctioned individuals and entities in different jurisdictions collectively estimated to be worth hundreds of millions of dollars.

The rationale behind these seizures, is to impose “significant costs on Russia, its leadership, and those who enabled Putin’s unprovoked invasion into Ukraine” and “deny safe haven for their ill-gotten gains.”

It is worth mentioning by the same token that Russia has launched a tit for tat “kidnapping” of Western assets located in Russia in retaliation for the seizure of Russian assets. The most noteworthy being the 515 foreign aircraft leased from abroad worth about $10bn (£7.7bn) that will have one heck of hard time finding their way back home after they are re-registered in Russia.

REPO can count on its little brother Task Force Klepto

On March 2, we reported that the US Department of Justice, launched Task Force KleptoCapture (doesn’t the name sound like a superhero?), to help support the REPO international effort.

Task Force Klepto will essentially deploy the US prosecutorial and law enforcement resources needed to identify sanctions evasion and related criminal conduct. I’m not sure whether the other  member countries have likewise launched & named their respective task force.

FinCEN

Treasury’s Financial Crimes Enforcement Network (FinCEN) will increase intelligence & information sharing with members of the Task Force. FinCEN will also release an Alert for financial institutions about the importance of identifying and reporting suspicious transactions by sanctioned Russian elites, oligarchs, and their proxies that involve real estate, luxury goods, and high-value assets.

On March 7th, we reported that FinCEN issued an alert listing red flags to help recognize Russian sanction evasion attempts. We also mentioned now would be a good time to speed up the publishing of beneficial ownership registries ( on which the US is overdue) since one of the most common sanction evasion technique is the use of anonymous shell companies.

But the best part of all:

 

The Reward Program

The US Treasury announced the launch of a bounty program under the Kleptocracy Asset Recovery Rewards Program, specific to Russia which offers rewards payments of up to $5,000,000 for information leading to seizure, restraint, or forfeiture of assets linked to foreign government corruption, including the Government of the Russian Federation.

I had covered the Kleptocracy Asset Recovery Program when it was announced in 2020 in more details in this article. The Program was essentially put in place to pay rewards to qualified individuals who provide information leading to the restraint or seizure, forfeiture, or repatriation of “stolen assets,” as defined by the law, linked to foreign government corruption.

For the Russia program:

“The U.S. Department of Justice, the Federal Bureau of Investigation and other U.S. law enforcement agencies seek information leading to the seizure, restraint, forfeiture, or repatriation of assets linked to corruption involving the government of the Russian Federation that are:

(1) in an account at a U.S. financial institution, including a U.S. branch of a foreign financial institution;

(2) that come within the United States; or

(3) that come within the possession or control of any U.S. person.  Persons who provide such information may be eligible for a reward under this Program or others. “

The program does not discriminate, so the tip could come from a non-US person, too ( subject to some conditions).

The Department of the Treasury’s Office of Terrorism and Financial Intelligence will administer the Program in coordination with the Departments of Justice and State and US federal law enforcement agencies.

Just in the event you were interested in other rewards under the Kleptocracy Asset Recovery Rewards Program, the U.S. Department of Justice and the Federal Bureau of Investigation are also seeking information leading to the seizure, restraint, forfeiture, or repatriation of bribes or assets linked to bribes paid by Odebrecht S.A. and Braskem S.A and those linked to corruption involving the Sovereign Wealth Fund of Malaysia, known as 1MDB. 

More information and frequently asked questions about the program could be found here.

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