Asset tracing across the former Soviet space: what still works

Tracing assets linked to a person or company in Russia, Central Asia or the South Caucasus has become harder. In recent years, access to some property, corporate and financial records has narrowed. Some registers that were once searchable from abroad are now limited to domestic users or unavailable. In some property registers, third parties can no longer obtain owners' personal details without consent. In some jurisdictions, certain companies may now withhold corporate or financial information that was previously public. These changes vary by country and continue to shift, so any assumption about access should be tested at the time of research.

The work remains possible. It depends more than before on combining many partial sources, and on recording exactly where each finding came from.

Domestic records that still work

• Corporate registers and their histories. Current and historical extracts show changes of ownership, management and address, and a transfer of shares shortly before a dispute can be significant.
• Court records. Judgments and case materials in commercial, civil and family disputes often describe property, shareholdings, loans and accounts in detail.
• Bankruptcy records. Insolvency notices and reports by insolvency officeholders can list assets, creditors and transactions under challenge.
• Enforcement records. Published databases of enforcement proceedings show unpaid judgments and debts, which can point to assets and to disputes elsewhere.
• Public procurement. Contract awards show which companies receive state money and, read alongside registers, can link a person to businesses that do not carry their name.
• Media and archived web material. Older press reports, company websites and web archives can preserve information that has since been removed from official sources.

Each of these sources has gaps. Court databases may omit cases or redact names. Some historical records can only be requested through domestic procedures. Used together, the sources often confirm one another or expose inconsistencies that merit further work.

Looking beyond the region

Assets connected to the region are often held elsewhere, and the records of other jurisdictions can be more accessible than domestic ones. In the UK, Companies House records include persons with significant control, title registers for property in England and Wales can be obtained from HM Land Registry, and the Register of Overseas Entities records beneficial ownership information for overseas entities that hold UK property, although some details, including information about trusts, are not published. In the EU, company and property registers vary by member state, and public access to beneficial ownership registers was restricted in a number of member states after a 2022 ruling of the Court of Justice of the EU, and the rules on access continue to change. In the UAE, corporate records are divided between federal, emirate and free-zone authorities, and public access to ownership information is limited. Offshore centres generally publish little about ownership, although court and insolvency proceedings there can be informative.

Consider a hypothetical. A debtor's domestic property records are closed to third parties, but a judgment in a commercial dispute at home refers to a loan secured on a flat in London. The title register for that flat names an overseas company as proprietor, and the Register of Overseas Entities lists that company's beneficial owner. Each step rests on a public record, and each can be documented.

Lawful methods and data protection

We use lawful methods only. That excludes pretexting, unauthorised access to systems, inducements to officials and the use of leaked databases of unlawful origin, which circulate for some countries in the region. Beyond the legal risk, material of uncertain origin can be inaccurate and can undermine the case it was meant to support.

Asset tracing almost always involves personal data. Under the UK GDPR, the EU GDPR and comparable laws, processing needs a lawful basis, must be proportionate and should be limited to what the purpose requires. Data protection laws in the countries concerned may also apply. Sanctions add a further layer, since assets linked to designated persons raise questions about dealing, licensing and reporting that counsel must address.

Grading and documenting findings

Tracing findings are often destined for counsel, who may rely on them in applications such as freezing orders, disclosure requests or enforcement proceedings. That places a premium on documentation. Each finding should record its source, the date it was obtained and the method used, with a copy preserved. Each link between a person and an asset should be graded, distinguishing documented ownership from indications of beneficial interest and from association alone.

A finding that cannot be traced back to a lawful source is one that counsel may be unable to rely on.

Our approach is to treat narrowing access as a reason for more method. We combine domestic and foreign records, state the confidence attached to each conclusion and make clear where a lead depends on inference. Presented this way, findings show counsel what each conclusion rests on.