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Uncovering Hidden Sanctions Risks for a Global Wealth Management Firm

Uncovering Hidden Sanctions Risks for a Global Wealth Management Firm

At the outset of the Ukraine–Russia conflict, a U.S.-based wealth management firm with a global client base faced a critical risk related to unknowingly holding funds from sanctioned individuals and entities. We were engaged to investigate the firm’s potential exposure, which led to the identification of several hundred entities linked to sanctioned individuals, allowing the client to proactively mitigate regulatory, legal and reputational risks.

Challenge

With international clients and alternative investment fund accounts, our client in the wealth management industry faced a growing concern—its potential exposure to sanctioned entities. The complexity of modern financial structures, particularly nested accounts and hidden beneficial ownership made it difficult to detect whether funds under management were linked to restricted individuals or organizations. High-risk jurisdictions such as Cyprus, Switzerland and Monaco further complicated the investigation, as these locations are known for complex corporate and investment fund structures designed to obscure ownership. The firm lacked the internal capabilities to conduct the level of deep-dive analysis required to untangle these risks. 

Solution

In response to our client’s need for support, Dominion Advisory Group—now part of SolomonEdwards—deployed a specialized team of financial crime experts, combining technology-driven data extraction and filtering capabilities with senior investigative professionals skilled in tracing international fund movements.  

Our team conducted extensive data mining to uncover hidden relationships between account holders and sanctioned entities. With our deep expertise in alternative investment partnerships, we were able to analyze opaque ownership trails within private equity and hedge fund structures. This allowed us to map out complex corporate hierarchies across high-risk jurisdictions, identifying accounts linked to restricted parties. 

By integrating advanced data analytics with investigative expertise, we provided the firm with a clear picture of its exposure, ensuring all identified accounts were thoroughly reviewed and assessed. 

Outcome

The investigation uncovered several hundred entities connected to sanctioned individuals, whose funds were embedded in limited partnerships and other difficult-to-trace investment vehicles. Equipped with these findings, the client swiftly reported the activity, exited the affected accounts, and reinforced its compliance measures to prevent future exposure. As a result, the firm successfully mitigated regulatory enforcement risks, safeguarded its reputation, and strengthened its commitment to financial integrity. 

Our work with this client highlighted the importance of proactive financial crime investigations in today’s regulatory landscape. With sanctions enforcement remaining a priority, particularly in light of global geopolitical tensions, financial institutions must ensure their compliance programs are robust enough to identify and mitigate hidden risks before regulators do.

 

Dominion Advisory Group, now part of SolomonEdwards, brings specialized expertise in anti-money laundering (AML) advisory and financial crime consulting. Learn more about our services in the Banking & Financial Services industry.   

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