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Security Brief: Illicit Finance and Economic Threats Week of April 10, 2022

April 10 - 13, 2022 | Issue 3

Jennifer Kelly, Illicit Finance and Economic Threats (IFET) Team

Alessandra Ciffo, Editor; Jennifer Loy, Chief of Staff

The Irish Flag[1]

Date: April 11, 2022

Location: USA

Parties involved: USA; US Department of the Treasury’s Office of Foreign Assets Control (OFAC); Kinahan Organized Crime Group (KOCG); Christopher Vincent Kinahan Senior; Daniel Joseph Kinahan; Christopher Vincent Kinahan Junior; Ireland; Ireland’s national police force (An Garda Síochána); UK’s National Crime Agency (NCA); Europol; United Arab Emirates; Spain; South America

The event: The OFAC has sanctioned the Irish KOCG and seven of its key members for their involvement in drug trafficking and international money laundering. The sanctions are a result of close collaboration between several international agencies, including OFAC, An Garda Síochána, the NCA, and Europol. The KOCG sources large quantities of drugs from South America to smuggle into Europe, while also engaging in a gang war with another organized criminal group in Ireland and Spain. Christopher Vincent Kinahan Senior and his two sons Daniel Joseph Kinahan and Christopher Vincent Kinahan Junior run the criminal enterprise from the UAE.[2]

Analysis & Implications:

  • The OFAC sanctions will very unlikely disrupt the KOCG’s criminal operations or impact its ability to generate funds due to its global illicit activities. The KOCG very likely takes advantage of weak anti-money laundering controls in the UAE to conceal the origins of its illicit finances, likely generating further funds for its criminal empire. Without extradition from the UAE, it is very unlikely law enforcement will be capable of stopping Christopher Kinahan Senior or his sons from conducting their international operations.

  • A lack of efficient financial controls and border security has very likely enabled the KOCG’s money laundering operations between Europe and the UAE. Increased collaborations between international law enforcement agencies will likely result in stricter enforcement of anti-money laundering regulations for financial institutions. Stricter financial controls will likely encourage the KOCG to engage in methods of laundering money, likely transferring illicit profits through cryptocurrency. Law enforcement will almost certainly be unable to detect illicit financial flows through the cryptocurrency market due to cryptocurrency’s decentralized nature.

Date: April 11, 2022

Location: EU

Parties involved: EU member states; Europol; European Financial and Economic Crime Centre (EFECC); Eurojust; European Border and Coast Guard Agency (Frontex); Sanctioned Russians; Law enforcement agencies; United Arab Emirates (UAE); Art dealers

The event: Europol launched Operation Oscar, an EU-wide operation to support financial investigations into sanctioned Russian individuals’ criminal assets. The EFECC, Eurojust, and Frontex will work together to facilitate EU member states’ exchange of intelligence and analyze all information to identify international links relating to sanctions on Russians. Frontex will also increase the scrutiny of individuals crossing EU’s external borders, meaning the operation will cover land, air, and sea. The operation is expected to continue for at least one year.[3]

Analysis & Implications:

  • By combining intelligence, European law enforcement agencies will very likely identify and freeze a greater number of assets belonging to sanctioned Russians, such as property and bank accounts. Some Russians will likely liquidate their EU-based assets and likely transfer their funds to regions with no sanctions, such as the UAE, to evade detection. Operation Oscar will unlikely expand to collaborate with the UAE law enforcement due to the European focus of the operation, meaning the UAE will unlikely flag suspicious financial transactions from sanctioned Russians to Europe.

  • Sanctioned Russian oligarchs will very likely evade sanctions and Operation Oscar by exploiting the anonymity in the high-value art market, likely disguising themselves as ordinary citizens to conduct art transactions. The subjective pricing of art almost certainly enables individuals to inflate the price of art pieces and likely transfer large sums of money without detection from law enforcement. This high value of art trades likely enables levels of corruption, and individuals will likely bribe art dealers to refrain from reporting suspicious activity.

________________________________________________________________________ The Counterterrorism Group (CTG)

[2] Treasury Sanctions Notorious Kinahan Organized Crime Group, US Department of the Treasury, April 2022,

[3] EU-wide operation targeting criminal assets in relation to the Russian invasion of Ukraine, Europol, April 2022,



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