Thread by @acdatacollectiv

Yesterday, @USTreasury alerted banks that sanctioned Russian 🇷🇺 elites are likely using US 🇺🇸 #CommercialRealEstate to evade sanctions.

fincen.gov/news/news-rele…

A couple of thoughts... 🧵

First, it’s welcome that FinCEN has recognized the opacity risks of CRE and issued guidance on identifying risky transactions. 👏👏

Hopefully new rules to prevent #RealEstate #MoneyLaundering due in April will cover both commercial and residential properties.

The alert also highlights the risks of pooled investment vehicles, where an individual’s stake is likely below banks’ reporting requirements. 👍

This loophole allows PEPs to fly below the radar by distributing their investment across multiple funds.🪆

Our 2021 report with @anticorruption using #OpenLux data makes the same point.

End investors in private investment funds usually don't appear in beneficial ownership data, making it easier to hide dirty money.

acdatacollective.org/work/in-the-da…

FinCEN can help combat #MoneyLaundering and other crimes hidden in #CRE deals by finalizing the 2015 rule on AML requirements for investment advisors.

acdatacollective.org/areas/private-…

To date, AML coverage of US real estate has been inherintly patchy, both geographically and by neglecting commercial properties.

A far more comprehensive system is needed.
Here are our recommendations:
acdatacollective.org/work/acdc-to-f…

Finally, we urgently need more intelligence on red flags and typologies of #sanctions evasion, money laundering and other #financialcrime in commerical real estate.

Together with @IllicitFlows, we’re already working on just that.