The advisory highlights that despite asset freezes, some Russian elites have evaded sanctions and maintained access to funds through:
- Family members and close associates;
- Real estate;
- Complex ownership structures;
- Enablers;
- Third-party jurisdictions and false trade information;
The advisory also sets forth recommendations for combatting sanctions evasion, which include:
- Ensuring compliance with national rules incorporating FATF Recommendations;
- Ensuring relevant AML/CTF compliance programmes are implemented and regularly reviewed;
- Partaking in existing public-private partnerships;
- Leveraging information sharing protocols;
- Updating risk assessments;
- Increasing awareness of sanctions risk and its impact for non-AML/CFTF regulated entities.
- Firms should read REPO’s advisory to learn more about Russian sanctions evasion and guidance on how to combat it.