In a joint statement released on June 29, the multilateral taskforce stated it has also “seized, frozen, or detained yachts and other vessels owned, held, or controlled by sanctioned Russians—including the Amadea, the Tango, the Amore Vero, the Rahil, and the Phi.” Additionally, REPO has “seized or frozen luxury real estate owned, held, or controlled by sanctioned Russians.”
REPO credited its collaboration with the private sector in promoting effective sanctions implementation. “Financial institutions and other entities required to comply with both sanctions and anti-money laundering and countering the financing of terrorism regulations have helped to identify and immobilize assets subject to sanctions and worked to prevent Russia from evading sanctions,” the task force stated. “Where available, REPO members have relied on the use of registries—such as bank account and beneficial ownership registries.”
Multinational Task Force
The REPO Task Force, established in February, consists of Finance Ministry and Justice or Home Ministry in each of the following member jurisdictions: Australia, Canada, Germany, France, Italy, Japan, the United Kingdom, and the European Commission. It is also supported by the United States’ Financial Crimes Enforcement Network (FinCEN). It was launched following Russia’s unprovoked invasion of Ukraine begun on February 24.
As task force members, each participating country has committed to using their respective authorities in concert with other appropriate ministries to collect and share information to take concrete actions, including sanctions, asset freezing, civil and criminal asset seizure, and criminal prosecution.
“Where appropriate and possible, REPO members are undertaking efforts to update or expand and implement their respective legal frameworks that enable the freezing, seizure, forfeiture or disposal of assets, for example within criminal law,” the task force said in its latest joint statement.
Other nations are also cooperating with the sanctions on Russian oligarchs. Fiji, for example, helped seize the $300 million yacht of sanctioned Russian oligarch Suleiman Kerimov. Fijian law enforcement executed a seizure warrant freezing the Motor Yacht Amadea, a 348-foot luxury vessel owned by sanctioned Russian oligarch Kerimov. Fijian law enforcement, with the support and assistance of the FBI, acted pursuant to a mutual legal assistance request from the U.S. Department of Justice following issuance of a seizure warrant from the U.S. District Court for the District of Columbia, which found that the Amadea is subject to forfeiture based on probable cause of violations of U.S. law, including the International Emergency Economic Powers Act (IEEPA), money laundering and conspiracy.
Ongoing Efforts
“In the coming months, REPO members will continue to track Russian sanctioned assets and prevent sanctioned Russians from undermining the measures that REPO members have jointly imposed,” the joint statement continued. “Together, we will ensure that our sanctions continue to impose costs on Russia for its unprovoked and continuing aggression in Ukraine and to prevent funds and economic resources from being provided to or for the benefit of designated persons.”
“As we undertake this work, we are seeking to maximize the impact of sanctions on designated persons and entities, while guarding against spillover that affects global commodities markets and food supplies, which Russia has disrupted by choosing and continuing to wage war.”
In March, FinCEN issued an alert to financial institutions on the importance of identifying and quickly reporting suspicious transactions involving real estate, luxury goods, and other high-value assets of sanctioned Russian elites and their proxies. The Alert provides select red flags to assist financial institutions in identifying suspicious transactions, and reminds financial institutions of their Bank Secrecy Act reporting obligations. 
Jaclyn Jaeger is a contributing editor at Compliance Chief 360° and a freelance business writer based in Manchester, New Hampshire.