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In July 2022, the UK’s National Economic Crime Centre (NECC), a multi-agency unit in the National Crime Agency (NCA), and HM Treasury’s Office of Financial Sanctions Implementation (OFSI), working in conjunction with the Joint Money Laundering Intelligence Taskforce (JMLIT) issued a red alert in which they identified various common evasion tactics and techniques used by suspects to avoid the UK’s financial sanctions regime with the help of professional enablers.
The red alert defines “enablers” as “individuals or businesses facilitating sanctions evasion and associated money laundering” and identifies a number of enabling “key professions”, including lawyers, accountants and wealth managers, estate agents, auction houses, and company directors.
The red alert identifies a series of indicators through which the work of professional enablers of evasion tactics may be unveiled:
Use of banks and financial organizations owned by close associates of designated persons.
Off-the-shelf corporations with no trading record with nominee ownership used as throughputs.
Intelligence indicating suspicious consulting invoices at exorbitant or clearly non-market rates.
Material indicating that an enabler’s own due diligence relies on a further layer of due diligence not actually conducted by themselves.
The use of a complex trust structure for the ownership of a luxury asset, which is overseen by a trust company and its trustees for no apparent legitimate reason.
Please find below the Red Alert "Financial Sanctions Evasion Typologies: Russian Elites and Enablers" (July 2022).
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