Property transfer records, OFAC enforcement actions, and Pandora Papers analysis reveal that sanctioned Russian individuals have systematically moved real estate assets out of Western cities into new offshore havens — using the same shell company structures that the sanctions were supposed to shut down.
The London Loophole
The International Consortium of Investigative Journalists documented how London properties linked to Putin allies remain untouched by sanctions years after designation. A five-floor townhouse on Herbert Crescent — connected to a sanctioned figure through the Pandora Papers — continues to be held via a British Virgin Islands shell company and trust structure that places it beyond the reach of UK sanctions enforcement.
Transparency International estimated that £1.5 billion worth of Russian-linked property exists in London alone — and acknowledged that the actual figure is likely far higher, given the opacity of offshore ownership structures. Properties held through layers of corporate entities, trusts, and nominees create legal barriers that sanctions enforcement agencies lack the resources and legal tools to penetrate quickly.
The American Enforcement Attempts
In the United States, OFAC has taken targeted enforcement actions against property management firms that facilitated transactions for sanctioned individuals. Gracetown, a New York property management firm, was penalized $7.1 million for processing transactions on behalf of sanctioned oligarch Oleg Deripaska. In a separate case, a U.S. person operating through King Holdings LLC in Atlanta was penalized $4.6 million for mortgaging and selling a sanctioned Russian-owned property between April 2023 and March 2024.
These enforcement actions demonstrate both OFAC’s willingness to pursue violators and the fundamental limitation of the sanctions regime: it depends on intermediaries — property managers, lawyers, bankers — either knowing about the sanctions and complying voluntarily, or being caught after the fact. The penalties, while significant, arrive after the property transfers have already occurred.
The New Havens
The sanctions pressure on Western real estate has not eliminated Russian oligarch property holdings — it has redirected them. Assets are moving from London and New York to jurisdictions with weaker enforcement: Dubai, Istanbul, the Caucasus, and Central Asian capitals that maintain working relationships with Moscow. The wealth isn’t disappearing. It’s relocating to addresses where sanctions enforcement is nominal or nonexistent.
The Pandora Papers revealed the architecture of this wealth movement: layered corporate structures spanning multiple jurisdictions, nominee directors who provide deniability, and trust arrangements that separate legal ownership from beneficial control. These structures were built before sanctions and remain operational after them — because the jurisdictions that enable them have no incentive to cooperate with Western enforcement.
The Enforcement Deficit
The gap between sanctions policy and sanctions reality in the real estate sector is a function of structural limitations that no amount of political rhetoric can overcome. Property ownership records are fragmented across thousands of jurisdictions. Beneficial ownership registries remain incomplete in most countries. And the legal professionals who structure the transactions have professional obligations to their clients, not to sanctions enforcement agencies.
Until Western governments invest in the enforcement infrastructure necessary to make sanctions effective — mandatory beneficial ownership disclosure, international data sharing agreements, and penalties severe enough to deter facilitators — the oligarchs will continue to own their mansions. The sanctions will continue to exist on paper. And the gap between the two will continue to undermine the credibility of the entire regime.
Eduardo Bacci is an investigative journalist at The Investigative Journal. Data sources include OFAC SDN lists, ICIJ Pandora Papers database, and Transparency International property analysis.