The Compliance Kitchen, hosted by Silvia Surman, dives into detailed and complex topics looking at all sides of the compliance industry. The recent advisory from the repo task force that Silvia discusses reveals the clever evasion tactics used by Russian elites, including the beneficial ownership of legal entities transferred to their children, as well as enablers performing certain functions on their behalf. Russian and other users are able to access sensitive goods and technologies by using freight forwarding businesses in a third country. The Compliance Kitchen is here to provide insight and analysis into these and other compliance topics in an engaging and educational manner.
Key Highlights
Russian Sanctions Evasion Tactics Used by Elites. 00:06
The Use of Enablers to Avoid Sanctions on Russian Oligarchs. 06:13.
Illegal Access to Sensitive Goods and Technologies Through Freight Forwarding Business. 12:18
Notable Quotes
- “This is a multilateral effort that has used information sharing and coordination to isolate and pressure sanction Russian individuals and entities.”
- “The typologies that they identified in this advisory include the use of family member burs and close associates to ensure continued access and control over assets.”
- “The asset transfers it’s being observed that go to family members and close associates sometimes occur immediately before a person is on sanctions list or shortly thereafter. So that indicates sanctions evasion efforts.”
- “More specifically, the advisory tells us that sanctioned Russian individuals and entities have used the use of expensive real estate to hold value or to own their illicit proceeds through real estate using complex ownership structures to avoid identification of the ultimate beneficial owner.”
