The Financial Crimes Enforcement Network (FinCEN) has recently issued an alert cautioning all financial institutions regarding potential investments in the U.S. commercial real estate (CRE) sector, by or on behalf of sanctioned Russian elites, oligarchs, their family members, and entities through which they act. This alert complements sustained efforts of the U.S. government, in response to Russia’s war against Ukraine, to isolate sanctioned Russian persons from the international financial system. It highlights specific vulnerabilities to sanctions evasion in the CRE sector, which may be exploited by Russian elites or their proxies, and is based on a recent review of Bank Secrecy Act (BSA) reporting. It also provides financial institutions with guidance on identifying potential red flags and typologies of sanctions-evasion activities.

The Financial Crimes Enforcement Network recently issued an alert cautioning all financial institutions about potential investments in the U.S. commercial real estate sector, by or on behalf of Russian elites and their proxies. FinCEN’s communication complements U.S. efforts, in response to Russia’s war against Ukraine, to isolate sanctioned Russian persons from the international financial system.

Regal Healthcare Capital Partners has invested in Sena Health, according to a news release.

Sena, based in Philadelphia, provides at-home care in partnership with healthcare providers. Founded in 2020, the company supports patients with a range of medical conditions throughout Philadelphia and the Southern New Jersey region.

Regal, based in New York, is a healthcare

Renovus Capital Partners has announced it has made a majority investment in ToxStrategies. 

ToxStrategies, based in Katy, Texas, is a multidisciplinary scientific consulting firm. Founded in 2008, the company’s client base includes pharmaceutical companies, medical device companies, health and beauty care companies, and government agencies.

Renovus, based in Philadelphia, is a lower middle market private

Alpine Investors has announced it has invested in Medusind.

Medusind, based in Miami, is a provider of healthcare revenue cycle management services. Founded in 2002, the company’s technology suite includes the MedClarity practice management software and the QuickVerify dental insurance eligibility and benefits verification solution.

Alpine Investors, based in San Francisco, is a private

UPDATE: U.S. Attorneys’ Offices Adopt Policy Incentivizing Self-Disclosure of Corporate Misconduct (Feb. 27, 2023)

On January 17, 2023, Assistant Attorney General (AAG) Kenneth A. Polite, Jr. delivered remarks to an audience at the Georgetown University Law Center, announcing changes to the Criminal Division’s Corporate Enforcement Policy (CEP). These changes to the CEP follow the September 15, 2022 direction from U.S. Deputy Attorney General Lisa Monaco, which we previously covered, for each Department of Justice (DOJ) Department to publish policies around voluntary self-disclosure, and to clarify the benefits of self-reporting. Although the Criminal Division already has such a policy, AAG Polite noted that the DAG’s direction was an opportunity to take stock of the existing policy and strengthen it.

InTandem Capital Partners has announced it has completed a strategic equity investment in HouseWorks.

HouseWorks, based in Woburn, Mass., is an independent home care company. Founded in 1999, the company serves Greater Boston, Philadelphia, New Hampshire and Southern Maine

InTandem, based in New York, focuses on acquiring middle market healthcare and insurance companies.