An investigative team led by iStories and the OCCRP shed light for the first time on how heavily-sanctioned individuals evade such sanctions. More than 60 journalists combed through 50,000 documents from 2013-2020 and all related to Boris and Arkady Rotenberg, prominent members of Russian President Vladimir Putin’s inner circle.
Diego Mintz
These documents revealed the intricate schemes utilized by the Rotenbergs — first sanctioned by the US in 2014 following Moscow’s annexation of Crimea — to avoid the freezing or confiscation of their assets.
In just the first day since the investigation was published, several articles have been written revealing how Western individuals and companies helped the Rotenbergs move around, conceal, or distribute their wealth among family members and acquaintances. Yachts, mansions, and bank accounts worth millions have been part of the complex maneuvers carried out by various facilitators.
While previous leaks like the Panama and Pandora Papers served as starting points for dozens of investigations worldwide, the Rotenberg Files are a detailed, granular study of how a single family, through a few points of contact, can influence bankers, lawyers, and corporate service providers in order to maintain illegitimate control of their assets. As some of the articles have demonstrated, these actors can be tempted for a fee to turn a blind eye to the use of fronts or spiderwebs of companies with intentionally misleading or unclear ultimate beneficial owners (UBOs).
For anti-money laundering (AML) professionals, these revelations offer valuable insights into the modus operandi of sanctioned individuals and their enablers. They provide a framework to consider potential practices and structures adopted by new offenders, regardless of their level of prominence.
For decision makers, the concrete revelations that will emerge could prompt direct action on their end, as they or their clients may discover that they were directly or indirectly exposed to bad-faith actors in this global intertwined map of sanctions and evasions.
At the same time, the current sanctions landscape is not entirely the same as it was at the time of the leaked documents. Following the global waves of sanctions sparked since the invasion of Ukraine in February 2022, more emphasis has been placed not only on entire sectors and companies, but also on the individuals exposed to the main designated targets. Nonetheless, the Rotenberg Files will remain a valuable reference and resource for identifying patterns in money laundering and illicit maneuvering.