The Sanctions Evasion Threat
Six Common Typologies All Compliance Officers Should Know
📅 November 26, 2024
📅 November 26, 2024
The global campaign of sanctions against Russia since February 2022 has turned sanctions evasion into one of the most important topics in the sanctions space.
Multiple industries are vulnerable to sanctions evasion activities, including exporters and importers, shipping, NGOs, insurance, and the financial sector. The financial sector is at particular risk because many of the industries vulnerable to sanctions evasion rely on the financial sector to help service, intermediate, or facilitate cross-border financial activity and trade. It’s more important than ever for compliance professionals to understand and recognize common sanctions evasion typologies.
Individuals and entities use several methods for circumventing sanctions. The methods they use are constantly changing in tandem with increased crackdowns on sanctions evasion. The following are six typologies describing some of the most used methods illicit actors use to evade sanctions.
Sanctions evaders leverage their money laundering expertise, using front and shell companies to hide the origin of their funds and place them into financial institutions typically outside of their jurisdiction.
A major benefit of using front or shell companies is to circumvent list-based sanctions. By doing so they can obscure (1) ownership; (2) source of funds; and (3) the countries involved.
Several Financial Intelligence Unites (FIUs) have issued alerts warning the public about the common practice of transferring assets to family members and/or close associates by sanctions targets to avoid their assets getting frozen. Such transfers have taken place in different forms:
Examples of this are fake or falsified invoices, bills of lading, corporate agreements, or loan documents; obscuring the true nature of business activity by using wrong or catch-all corporate registry business identification codes; and issuing corporate agreements with no underlying business purpose, like unconditional or near-zero interest loans from one offshore company to another.
We’ve seen this with corporate restructuring to avoid the application of OFAC’s 50 Percent Rule or the EU ownership/control restrictions. For example, lowering the sanctioned party’s ownership from 51% to $47%.
We’ve also seen changes of corporate ownership through an intricate web of offshore companies, sometimes including the creation of so-called “one day” companies to further obfuscate ownership, and often using generic names like “Logistics Solutions LLC.”
This is a common typology especially for Russia sanctions targets, which have used jurisdictions outside of Russia for bank accounts, company formation, and indirect imports or payments.
What are some red flags financial institutions can look for?
While large scale evasion by governments is not necessarily achievable or practical because of liquidity and other limitations, we’ve seen Iran and Russia legalize the use of cryptocurrency for international payments to support cross-border trade that has been subject to sanctions and related restrictions.
We’ve also seen many examples of the use of digital assets and digital asset service providers to evade sanctions by illicit actors and networks—including terrorist groups and state-sponsored cyber hacking groups—looking to obfuscate the origin, destination, and counterparties of transactions. Much of this has been exposed by public designation actions by the U.S. and other governments.
These examples and typologies represent a sampling of some of the most common methods illicit actors have embraced to evade U.S. and multilateral sanctions. Understanding them is an important starting point for private sector firms in assessing and responding to their exposure.
Sign up for the Dedicated Online Financial Integrity Network (DOLFIN). A powerful resource for industry professionals, membership grants unlimited access to our extensive library spanning the core financial integrity topics.
This site uses cookies. By continuing to browse the site, you are agreeing to our use of cookies.
Accept settingsHide notification onlySettingsWe may request cookies to be set on your device. We use cookies to let us know when you visit our websites, how you interact with us, to enrich your user experience, and to customize your relationship with our website.
Click on the different category headings to find out more. You can also change some of your preferences. Note that blocking some types of cookies may impact your experience on our websites and the services we are able to offer.
These cookies are strictly necessary to provide you with services available through our website and to use some of its features.
Because these cookies are strictly necessary to deliver the website, refusing them will have impact how our site functions. You always can block or delete cookies by changing your browser settings and force blocking all cookies on this website. But this will always prompt you to accept/refuse cookies when revisiting our site.
We fully respect if you want to refuse cookies but to avoid asking you again and again kindly allow us to store a cookie for that. You are free to opt out any time or opt in for other cookies to get a better experience. If you refuse cookies we will remove all set cookies in our domain.
We provide you with a list of stored cookies on your computer in our domain so you can check what we stored. Due to security reasons we are not able to show or modify cookies from other domains. You can check these in your browser security settings.
These cookies collect information that is used either in aggregate form to help us understand how our website is being used or how effective our marketing campaigns are, or to help us customize our website and application for you in order to enhance your experience.
If you do not want that we track your visit to our site you can disable tracking in your browser here:
We also use different external services like Google Webfonts, Google Maps, and external Video providers. Since these providers may collect personal data like your IP address we allow you to block them here. Please be aware that this might heavily reduce the functionality and appearance of our site. Changes will take effect once you reload the page.
Google Webfont Settings:
Google Map Settings:
Google reCaptcha Settings:
Vimeo and Youtube video embeds:
You can read about our cookies and privacy settings in detail on our Privacy Policy Page.
Privacy Policy