Red alert for sanctions evasion by sanctioned Russian elites

Financial intelligence sources have identified sanctioned Russian individuals using a range of methods to evade sanctions imposed following the invasion of Ukraine.

This includes using family members and associates to access, transfer and/or sell frozen assets through UK facilitators.

Sanctions Circumvention Indicators

Indicators of sanctions evasion methods identified by JMLIT include:

  • changes in the beneficial ownership of corporate structures to non-Russian or dual citizenship family members or associates
  • use of trust agreements or complex corporate structures involving offshore companies
  • person-related clients seeking to transfer all assets to other financial institutions and close accounts in the UK
  • change of address and name of Russian entities before the invasion of Ukraine
  • suspicious consulting bills at exorbitant or obviously out-of-market rates
  • holding companies based in offshore jurisdictions or those related to assets in the former Soviet Union
  • payments via fintechs partly owned by Russian nationals and/or others involved in previous large trade-based money laundering schemes (often involving Baltic and Nordic states)

For the complete list, Download Red Alert: Typologies of Financial Sanction Evasion: Russian Elites and Catalysts (PDF 290 KB).

How to protect yourself and your business

The JMLIT sets out a number of recommendations, in particular for:

  • document arm’s length transactions
  • be alert to breaches of due diligence to customers
  • carefully assess complex corporate structures with increased due diligence for high-risk clients
  • contact the Office of Financial Sanctions Implementation if there is reason to believe that a purported change of ownership has not been properly transferred

In addition, the working group recommends including code XXJMLXX and reference 0697-NECC if you decide to report suspicious activity.

Download the Red Alert: Typologies of Circumventing Financial Sanctions: Russian Elites and Enablers (PDF 290 KB)

The National Economic Crime Center has approved sharing this alert with members of the Bar.