Financial sanctions evasion typologies: Russian elites and enablers
On 13 July 2022, the Minister for External Relations and Financial Services published a Financial Sanctions Notice regarding a red alert issued by the National Crime Agency (NCA) and HM Treasury’s Office of Financial Sanctions Implementation (OFSI).
Financial Sanctions Notice 13 July 2022 (gov.je)
The purpose of the alert is to provide information from law enforcement and the legal and financial services sectors on some of the common techniques designated persons and their UK enablers are suspected to be using to evade financial sanctions.
All supervised persons are obligated to implement sanctions screening and have adequate policies, controls and procedures in place to effectively identify and mitigate risks the business faces, including appropriately identifying and dealing with sanctioned entities. Breaches of financial sanctions are criminal offences.
We encourage you to review the alert and to use it to complement your existing knowledge about sanctions evasion techniques and to support on-going improvements to your business policies and procedures.
For more information visit our dedicated sanctions resources available on our website and the relevant Government of Jersey’s website page.
Sanctions — Jersey Financial Services Commission (jerseyfsc.org)