News & insights

REPO Task Force on Sanctions Evasion

Written by Insight & Partnership Team | Mar 9, 2023 3:06:00 PM

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.