DOJ Launches “KleptoCapture” Task Force

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DOJ Launches “KleptoCapture” Task Force

ilan.graff@friedfrank.com's picture
Commentary by Ilan T. Graff

The DOJ launched an interagency force dedicated to enforcing the sanctions, export restrictions, and economic countermeasures imposed as a response to Russia’s invasion of Ukraine.

“Task Force KleptoCapture” is intended to take actions consistent with announced sanctions to (i) isolate Russia from global markets and (ii) target the crimes of Russian officials, government-aligned elites, and those who aid or conceal their unlawful conduct. These actions include:

  • investigating and prosecuting violations of sanctions imposed following the Ukraine invasion, as well as sanctions imposed for prior instances of Russian aggression and corruption;
  • combating unlawful efforts to undermine restrictions taken against Russian financial institutions;
  • targeting efforts to use cryptocurrency to evade U.S. sanctions; and
  • using civil and criminal asset forfeiture authorities to seize assets belonging to sanctioned individuals or assets identified as the proceeds of unlawful conduct.

Commentary

The Task Force will be led by longtime SDNY prosecutor Andrew Adams, who most recently served as the co-chief of the office’s Money Laundering and Transnational Criminal Enterprises Unit.  Adams is an entrepreneurial and tenacious prosecutor who brings deep familiarity with criminal and civil forfeiture law, as well as strong relationships with the FBI’s Eurasia-focused investigators and other key agency partners.  (See here, for a further reference to Adams’ leadership of the group.) Sanctions enforcement has sometimes been hampered by the complexities of the inter-agency process and delays in sharing information across borders.  If DOJ can sustain the level of partnership and foreign cooperation suggested by the Attorney General’s announcement, “KleptoCapture” could set a new standard for the Department’s sanctions enforcement regime.