How to Trace Hidden Foreign Assets of a Sanctioned Suspect
A sanctioned suspect re-registered assets to intermediaries in Ukraine to dodge sanctions and nationalization. ARMA had a domestic trail and a question no domestic record could answer: what did the suspects control abroad?
3 Foreign jurisdictions surfaced through Sayari
4 Suspects linked to foreign entities
2 Countries where foreign assets were confirmed
The challenge: a domestic evasion scheme, an open question abroad
A Ukrainian law enforcement authority came to Asset Recovery & Management Agency (ARMA) with a request: trace the assets tied to a criminal investigation into document forgery and large-scale money laundering.
The case centered on individuals and foreign legal entities already under Ukrainian sanctions, including asset-blocking measures that prohibited the use or disposal of their property. Before those sanctions landed, one suspect (Suspect 1) held effective control over a group of Ukrainian companies. Under the law, the assets of those companies counted as assets controlled by a sanctioned person.
Then the trail went cold on purpose. Investigators suspected that, once sanctions took effect, Suspect 1 and several associates re-registered the companies’ Ukrainian assets to intermediary entities, circumventing the sanctions and avoiding future nationalization. The same group was believed to have laundered assets of particularly large value.
Domestic tracing could follow the assets to the edge of the map. It could not follow them past it.
How ARMA used Sayari to link the suspects to foreign companies
ARMA ran a comprehensive asset-tracing exercise inside Ukraine. In parallel, ARMA analysts opened the Sayari Platform to find the international links investigators did not yet know existed.
A Commercial World Model resolves records into entities, connects those entities across borders, and traces every finding back to a primary source. For an analyst chasing ownership through intermediaries, that connective tissue turns a dead end into a next step.
Working through Sayari, ARMA established 4 links that reopened the case:
Czech Republic
Identified the corporate structure of a Czech company and established that Individual 1 was its founder.
United Kingdom
Identified a residential address for Suspect 1 in the UK, giving investigators an additional jurisdiction for international enquiries. Individual 1 was its founder.
Slovakia
Uncovered the ownership structure of several Slovak companies and identified Suspects 2 and 3 as founders of these foreign companies.
Slovakia
Identified that Suspect 4 holds a Slovak Individual Tax Number, tying a fourth suspect to the same jurisdiction.
The results
Turning the findings into formal international asset-tracing requests
The intelligence generated through Sayari was shared with the investigative authority immediately. ARMA did not stop at a lead. It converted each link into action.
Based on the findings, ARMA submitted international asset-tracing requests to the competent authorities of Slovakia, the Czech Republic, and the United Kingdom, verifying the identified information and establishing whether assets belonging to the suspects sat abroad.
The result: vehicles, real estate, and bank funds located abroad
Following the Sayari analysis, international cooperation confirmed assets held by the suspects in foreign jurisdictions.
“International asset tracing often requires specialists to look beyond the information initially available in a criminal investigation. Sayari helps our specialists uncover previously unknown corporate structures and international connections, which can open new directions for asset tracing. In this case, the information identified through the platform enabled ARMA to initiate targeted requests to foreign jurisdictions and ultimately contributed to the identification of assets abroad.”Anna Makarenko, Head of the Department of Finding, Tracing and Recovery of Assets in Foreign Jurisdictions, ARMA
Vehicles, real estate, and bank funds located abroad
Slovakia
Assets identified
- Motor vehicles
- A shareholding in a Slovak company
United Kingdom
Assets identified
- A land plot
- Real estate property
- Funds held in bank accounts
IMPACT
Foreign holdings the domestic trail could not reach are now on the record
The intelligence generated through the platform enabled ARMA to identify additional foreign jurisdictions, initiate targeted international cooperation, and confirm previously unidentified assets held abroad that may become subject to further legal measures. The connections that opened those jurisdictions were sitting in the world’s commercial record, waiting to be resolved.
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