WHO SUPPLIED WAGNER AND OTHERS WITH GREENBACKS TO PAY ITS MERCENARIES FIGHTING FOR RUSSIA IN THE UKRAINE?

A good compliance officer can consistently spot critical information buried within news articles dealing with non-financial subjects. Today's extract deal with a story about how a notorious Russian neo-Nazi paramilitary group, known as the RUSICH GROUP, and whose mercenary soldiers have reportedly refused to continue to fight in a critical battle involving Ukraine's much-anticipated counteroffensive near Crimea. Apparently its leader, a Norwegian with dual Russian nationality, has been arrested in Finland, and is looking at probable extradition to face war crimes charges in a Ukrainian court. 

While the story raises the issue of how an individual from a Nordic country that is a staunch NATO Member ended up as a mercenary commander, the most important gem of information contained inside the article is the fact that YVGENY PROGOZHIN the late leader of Wagner, until recently the largest mercenary component fighting in the Ukraine for Russia, had a policy of paying his soldiers well, and in US Dollars, and that this practice had spread to the other mercenary units operating there.

Ruble a/k/a Rouble

Whilst it is understandable that the soldiers would not be happy to be paid in Rubles, as the Russian currency is presently worth around one US Cent ($.01), compliance officers should certainly be curious about just how these sanctioned organisations came to possess large amounts of Greenbacks. Were banks in Austria or Switzerland the culprits, as both countries are neutrals, and are not members of NATO ? We cannot say, but an effective compliance officer or director at international banks in both countries, having seen the story in French media, would govern himself or herself accordingly.

Being a compliance officer is as much about being a detective as one who is charged with CIP, or with transaction monitoring; it is about your ability to ferret out important information from all open-source material daily, and by promptly acting in response to it; Pay attention.