In the shadow of Russia’s horrific war with Ukraine, governments, companies, and individuals are taking action to restrict the financial capabilities of Russia’s oligarchs.
Corporations are rushing to distance themselves from Russian clients, but discovering which money is Russian is not easy in a world of shell companies and complex corporate structures. In addition, monetary claims against the Russian regime and its henchmen begin to arise, prompting law firms around the world to seek Russian assets on behalf of their clients.
Andrew Adams, head of the US government’s ‘KleptoCapture’ taskforce, describes recent evasion levels as reaching an ‘all-time high’ as frenetic attempts are made to cloak and conceal the assets of Russian oligarchs.
Russia’s super-wealthy have the resources to fund teams that are experts at obscuring and fragmenting the location and ownership of assets. Complex divisions of corporate, trust and nominee structures are used to hide Kremlin-linked cash, holdings and properties.
While the evasion techniques are sophisticated, so are the strategies developed by corporate investigators to effectively track and trace Russian assets. Cutting-edge digital technology can be combined with traditional forensic financial tracking to root out assets.
Investigators frequently find that assets, including those of Russian oligarchs, are hidden using the corporate equivalent of smoke and mirrors: sophisticated nominee or trust structures spread over a range of jurisdictions. Anyone who doesn’t want their assets to be traced has a range of options for obfuscation – from complex money laundering to tangled corporate structures.
Combining tech and traditional
An effective investigation is built on poring over databases, sifting through archives and on-the-ground data gathering trips. While the basics remain, some methods used to carry out these tasks have changed.
Social media and digital analysis are particularly powerful tools for asset ownership investigations. They exploit the instincts of high-net-worth individuals to share aspects of their lives with family and friends. While images and posts may be deleted, digital trails remain.
Specialized tools allow this data to be trawled, collated and analyzed to build detailed personal profiles of targets – their background, social/business networks, hobbies, lifestyles, properties and financial activities.
Even the most innocuous looking shared photos can reveal a wealth of information with images being processing through analysis software. Information can also be extracted from meta-data that can reveal the authorship, time and location of communications.
The power of data is maximized when combined with traditional asset-tracking methods. An example is a ‘selfie’ posted by a Russian businessman linked to the Putin regime that led to asset identification. Digital image analysis used elements in the background to provide a probable London location. This was followed up by boots-on-the-ground inquiries with a visit to the location, checks of local authority records and contacts with neighboring properties to confirm links and provide an exact match to the background elements in the original image.
Strategies for tracking Russian-owned assets
Investigations are typically split into a two-step process which begins with asset mapping. This is a systematic analysis of an individual’s global assets – what they are, where they are and how they were acquired. This information is then used to develop an asset recovery strategy which assesses the relevant pros and cons of enforcement.
The core of the work for corporate investigators lies in identifying attempts to hide tangible and intangible assets, thereby revealing the oligarchs behind investments.
Use available resources
US, UK and European authorities are collaborating as part of the Russian Elites, Proxies, and Oligarchs (REPO) task force to share resources designed to aid investigations into oligarch-held assets. This includes regularly updated lists of high-priority targets and financial incentives for successful asset identification.
Sanction tracking tools have also been created by organizations such as C4ADS and the Russian Asset Tracker provided by the Organized Crime and Corruption Reporting Project (OCCRP). These resources provide important information on what is known but also on those areas that remain unknown and where assets remain unaccounted.
For additional inspiration on OSINT (open-source intelligence) gathering, we recommend sites such as Bellingcat, an investigative journalism group.
Find the focus
The first step is identifying the individuals most likely to be oligarchs behind a corporation. Navalny 35 was created by the Anti-Corruption Foundation, listing the primary 35 oligarchs with close ties to Putin’s regime. All corporate investigators should have these names in mind when scouring through the financial information.
The distributed nature of global assets makes it essential to have a clear direction and goal. Building a personal profile is a vital part of achieving this, helping to focus investigations on areas and activities most likely to reap rewards.
By entering the ‘headspace’ of a Russian oligarch – getting a feel for their habits, history and motivations – you can develop an appropriate investigation strategy to target locations and data sources. This is guided by data analysis but ultimately relies on the instincts and knowledge of an experienced investigator.
Go beyond the individual
Oligarchs have resources to effectively cover personal data tracks linking them to asset holding. Much harder for them to achieve, however, is to cover the myriad of communications and connecting activities involving partners, family, friends, colleagues and associates.
A prime example is the social media activities of 21-year-old Russian student Polina Kovaleva which pictured her in a £4.4 million London luxury apartment. She was sanctioned by the UK government after links between her mother and Sergei Lavrov, Russian Foreign Minister, were established.
Develop a database and overview
Effective data management is essential when looking to reveal links and connections between individuals, organizations and assets. Create a digital database that allows key information to be easily updated, tracked and shared across an investigations team.
Keeping tabs on basic information such as names, dates of birth, addresses, company details and dates of financial activities is a simple but effective way to strip away layers of complication to reveal the basic asset relationships that exist beneath.
These steps will all produce vast amounts of data that will not be useful unless appropriately displayed. A wealth of free and paid data visualization software is available with the mapping of complex asset structures in mind. These tools can make the job of tracing connections and the flow of finance far easier for corporate investigators.
Check Russian asset declarations
A good starting point for any investigation is to check publicly accessible asset declarations of Russian public officials. This information covers politicians, government officials, judges and employees of state-owned corporations.
The information, which is collated by the Declarator website, includes basic details of property-related liabilities and covers globally held assets. While the data is basic, it helps to focus investigations on relevant countries and jurisdictions.
Use off-shore resources
Oligarchs will commonly use specialist lawyers to hide ownership behind multi-layered corporate structures that incorporate offshore tax haven status. Free resources such as OpenCorporates can help simplify the process of identifying connections and joining dots between entities.
The Offshore Leaks Database by the International Consortium of Investigative Journalists (ICIJ) also offers a valuable resource, providing access to the details of more than 810,000 offshore companies revealed through the Pandora Papers leak of more than 12 million documents.
For shell companies, the Panama and Paradise Papers are an excellent place to start, allowing investigators to track the origin and individual behind these shadowy entities. Some data will require investment to obtain, such as that on housing ownership. The HM Land Registry, for example, reveals exactly who owns property in the UK, but charges for business usage. Keep in mind that not all useful information is available on public databases, and it may be necessary to request additional data via a freedom of information request or going directly to a registry.
Track vehicle assets
Luxury yachts, jets and sports cars are an integral part of life for most Russian oligarchs. These provide a highly visible and traceable range of assets to target in each area an individual spends time. Tracking these movements can provide leads to connected assets, such as flights to a holiday home.
Public access tools such as VesselFinder and Marine Traffic provide a good starting point with more advanced options available, such as Icarus Flights, which provides uncensored aircraft activity data and global ownership records.
Take care with translations
A simple problem that can stifle the effectiveness of online investigations is transliteration caused by converting Cyrillic words into English. A common difficulty is the many ways Russian names can be converted into English, such as Dmitry, Dmitriy, Dmitri, Dimitri.
While most major search engines make allowances for these differences, many digital searches will require an exact match to display a result. Name variations should be recorded in the database, but generally having access to Russian speakers will be a major benefit for research work.
Only a fragment of public information is available through online searches and databases. Many authorities and institutions still require a request for information and may require a site visit for document and record checks.
Most nations now have some form of freedom of information law and it’s important to understand the powers available in a target jurisdiction. For smaller organizations, a physical visit will often be a more productive and cost-effective approach.
Often, the old-school investigative journalist’s approach of picking up the phone and calling sources, neighbors, ex-wives, or former business associates yield the most fruitful intelligence.
The benefit of a targeted approach is the ability to experiment with different methods to search for relevant information. This starts with basic public record checks but can include a limitless source of potential leads – forums, committee minutes, court records, flight patterns, auction catalogues, etc.
The more obscure a source is, the less likely that information is deleted or redacted. Familiarity with tools like Google Earth can be particularly effective when locating properties or identifying assets such as personal jets and yachts.
Any search should begin with public records, taking in corporate filings, property registers, and the media to assess the subject’s holdings. Surprisingly, HR files can also yield high-quality leads for identifying places, people, and contact information that can reveal a maze of companies and individuals that might be involved.
Following the money sounds like a cliche, but it’s true. If the company books are available, trusted, and do not involve cryptocurrencies, leads can be followed to the money.
For instance, payments for real estate agents’ fees could reveal clues as to the location of a property. Additionally, Swift messages used in international transfers can easily be reviewed.
Despite the ubiquity of encrypted VoIP, itemized mobile and landline phone bills still reveal international contacts not known to be linked to the subject. Mobile phones can offer a glut of information, including messages, geolocation information, and call mapping. A subject’s digital footprint can also reveal much, such as emails, documents, and internet searches.
The process can reveal the true owners of assets, provide leads and identify sources that can lead to assets that can become part of the legal recovery action. This is not always possible, as many assets are left in non-transparent jurisdictions. But even the most secretive oligarch may have a relative or friend who is overactive on social media, a tool that can help identify where assets might be hidden.
Top asset-hunting tips
- Where might you find what you seek? Oligarchs love their luxurious lives in New York and London, with rule-of-law protections; and Monaco, and Dubai, with light-touch regulation.
- An organized asset database is essential. Update it often and include names, contact info, company directors, asset values, acquisition and sale dates, company numbers, etc.
- Oligarchs often register assets under the names of family members or close confidantes for legal protection. Seek to identify wives, mistresses, children, parents, siblings, trusted friends, and business partners.