The United States instituted wide-ranging sanctions against Russian power elites in response to Putin's war of aggression on Ukraine. These sanctions are the most aggressive ever unleashed by the United States. They could turn out to be a decisive weapon. However, for these sanctions to become truly potent, government regulators need to unwind complex financial instruments specifically engineered to hide the assets the United States hopes to locate. Figuring out who owns what is something governments are not well equipped to do on their own. This difficulty is because bankers, accountants, and lawyers usually do off-shore transactions behind closed doors, all of whom have financial interests in keeping the ownership secret. For example, banks intentionally kept the illegal off-shore bank accounts held by United States citizens secret for decades until a UBS banker, Bradley Birkenfeld, utilized the 2010 Dodd-Frank Act to turn in the names of thousands of United States citizens holding illegal off-shore accounts. It is safe to say that without the enactment of whistleblower reward provisions found in the Dodd-Frank Act, those off-shore secret accounts would have continued to evade government detection. The same holds true with the Russian sanctions currently being pursued by the United States.
The Office of Foreign Assets Control (OFAC) of the U.S. Department of the Treasury administers and enforces sanctions established by the United States. Specifically, OFAC is tasked...
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