At the outset of the Ukraine–Russia conflict, a large U.S.-based wealth management firm with many international clients and alternative investment fund accounts became concerned about the risk of indirectly holding and managing funds from sanctioned individuals and entities.
Uncovering potential nested accounts and unknown beneficial owners required considerable data mining skills, expertise, and experience unraveling complex corporate and investment fund structures in high-risk locations such as Cyprus, Switzerland, and Monaco.
The client retained Dominion’s multi-disciplinary team of technology, data extraction, and filtering experts and our senior special investigators with years of experience tracing international funds movements, alternative investment partnership understanding, and opaque ownership trails to identify, investigate, and identify several hundred entities related to sanctioned parties whose funds were hidden in limited partnerships and other hard to unravel investment vehicles.
The client reported the activity, exited the accounts and relationships, and protected itself from regulatory, legal, and reputation risks. (153)