Disabling the enablers of sanctions circumvention

Think tank: RUSI

Author(s): Justyna Gudzowska; Eliza Lockhart; Tom Keatinge

May 7, 2024

This report from UK think tank RUSI illustrates how fundamental policy and practice gaps allow enablers to improperly protect assets and interests from sanctions.

This brief analyses a sample of over 100 relevant recent investigative reports, by OCCRP and other media outlets, on Russian and Belarusian individuals and entities who have been aided by professional service providers in their attempts to circumvent sanctions; as well as official US, UK and EU actions taken against professional enablers and their services since the full-scale invasion of Ukraine in February 2022.

Using this evidence base, and with an audience of policymakers in mind, this brief identifies common mechanisms by which professional service providers facilitate sanctions evasion and makes recommendations as to how policymakers can work together to minimise the use of professional service providers to circumvent sanctions.