The Russian Elites, Proxies, and Oligarchs [“REPO”] Task Force, a multi-lateral effort consisting of Finance Ministry and Justice or Home Ministry participants from member jurisdictions, has published a Global Advisory on Russian Sanctions Evasion.

REPO works to deny designated Russian elites and proxies access to revenue and goods that generate additional revenue, and prevent their procurement of sanctioned or export-controlled items.

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.

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