Sanctioned Russian individuals are using a range of methods, including trade-based money laundering (TBML), to evade sanctions imposed on them following Russia’s invasion of Ukraine according to financial intelligence sources consulted by the UK’s Joint Money Laundering Intelligence Taskforce (JMLIT).
Other methods include using family members and associates to access, transfer or sell frozen assets via non-Russian enablers according to the JMLIT’s Red Alert Financial Sanctions Evasion Typologies: Russian Elites and Enablers which catalogues and describes common techniques suspected of being used by sanctioned Russian elites and their enablers to evade sanctions.
Targeted at banks and the wider private sector with responsibilities for identifying participants in and enablers of sanctions evasion, the alert is potentially relevant to a worldwide constituency of institutions concerned with detecting sanctions evasion by Russian individuals.
Suspicious activity indicators
Indicators suspected of being used to evade sanctions by enablers include payments received by UK businesses, often in innovative areas, such as fintechs.
These include UK-registered payments service providers and electronic money institutes, owned in part by Russian nationals or others implicated in previous major TBML schemes, often involving the Baltic and Nordic states.
The JMLIT red alert also says circumvention attempts through open account TBML typology, such as increases in third party open account payments, may also indicate sanctions evasion.
Changes to beneficial ownership of corporate structures to non-Russian or dual national family members or associates is amongst other indicators of sanctions evasion methods identified in the alert.
Complex corporate structures involving offshore companies and holding companies based in offshore jurisdictions or those linked to assets in the former Soviet Union may also indicate sanctions evasion.
The JMLIT’s Red Alert Financial Sanctions Evasion Typologies: Russian Elites and Enablers provides a full list of methods used by Russian individuals to evade sanctions and can be found here.
Categories: Trade Based Financial crimes News