ARTICLE
1 January 2025

Investigation Into Financial Sanctions Circumvention

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Duane Morris LLP

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Switzerland's Federal Police Agency has revealed details of a major investigation into assets held by a sanctioned Russian oligarch, involving suspicious activity reports from Swiss private banks and international cooperation. The operation mobilized over 50 investigators and prosecutors across multiple cantons to search premises and seize bank accounts and real estate in what remains one of the largest money laundering cases aimed at evading sanctions.
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As part of the Annual Report for 2025, Switzerland’s Federal Police Agency (Fedpol) has included information on an investigation into Russian funds held by an unidentified sanctioned Russian oligarch (the report uses the name “Aleksandr*” but this is not the person’s real name.

The report makes mention of a number of suspicious activity reports filed by Swiss private banks, and cooperation with an unnamed foreign country led to a significant investigation:

The investigation revealed that Oleg and Dimitri owned assets in several cantons. The competent foreign criminal prosecution authority submitted a request for mutual legal assistance to the Federal Office of Justice with the aim of searching the premises and seizing the assets of Oleg and Dimitri, in particular bank accounts and real estate. A cantonal public prosecutor’s office was responsible for processing the request for mutual legal assistance. fedpol coordinated the case in Switzerland and abroad. By the end of 2025, the operation was underway, with more than 50 Swiss investigators and prosecutors from several cantons involved.

The seizures would first take place in Switzerland, with further actions in other European countries scheduled to follow. To this day, this remains one of the largest cases involving money laundering for the purpose of evading sanctions“.

The report does not discuss the outcomes of the investigation so far.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.

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