On 13 July 2022, the National Economic Crime Centre, a multi-agency unit in the National Crime Agency (NCA), and the Office of Financial Sanctions Implementation, working in conjunction with law enforcement and financial sector partners as part of the Joint Money Laundering Intelligence Taskforce, issued a Red Alert on financial sanctions evasion typologies that may be used by Russian elites and enablers to evade or circumvent UK financial sanctions restrictions.
The Red Alert highlights that some designated persons are using a range of techniques to transfer assets via enablers, i.e., businesses or individuals who facilitate sanctions evasion or associated money laundering, prior to sanctions being imposed or shortly thereafter. This enables the designated persons to claim that they no longer own those assets, although the Red Alert asserts that it is highly likely that the designated persons will retain influence over those assets through proxies or enablers.
The Red Alert lists particular indicators identified through NCA casework, open sources and risk monitoring that are suspected of being used to evade sanctions and that may be used to assist in the detection of frozen asset transfers, enablers and suspicious payments. Firms, particularly those in financial services and other regulated sectors, may wish to take these indicators into account when conducting sanctions risk assessments and due diligence.
Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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