Webinar | Reining in on Sanctions Evasion
Sanctions only work when they can be effectively enforced. Especially global Sanctions regimen are hard to track and with that even harder to enforce.
On the other hand, with evolving sanctions like the ones against Russia many companies and financial institutions find it hard to ensure that their business activities are compliant. Fines for non-compliance are high and the reputational risk sometime even higher.
Join us at this discussion, where our panelists will update us on both EU and US sanction developments and outline the most common and effective techniques to prevent and detect sanctions evasion. You will also learn about the biggest challenges companies, advisors, financial institutions and policy makers face to develop systems and new ways to collaborate to stay on top of the latest sanction developments.
I. Setting the stage
● Most common ways to avoid sanctions (shell companies, trusts, assets held in offshore jurisdictions, cryptocurrency, and opaque distributions chains)
● Most common techniques to prevent and detect sanctions evasion
– OFAC Red Flags: Obfuscation of Critical Information in Financial and Trade Transactions Involving the Crimea Region of Ukraine (July 30, 2015)
– What EU or member states guidance are there?
II. Sanctions evasion in the U.S.
● Regulators on high alert:
● Policymakers demand regulators’ vigilance
● US Enforcement:
– DOJ Task Force KleptoCapture
– First-ever Crimea-sanctions-related criminal indictment (March 3, 2022)
– Related indictment of Russian oligarch (Apr. 6, 2022)
– Treasury Targets Sanctions Evasion Networks and Russian Technology Companies Enabling Putin’s War (March 31, 2022)
– First forfeiture action against an oligarch’s property
III. Sanctions evasion in the EU
● EU regulations vs. national enforcements
– Lack of guidance from the European Commission
– Member states’ law enforcements – one vs. multiple players
– Enforcement throughout the EU is inconsistent
● “No activity – no risk to breach sanctions” approach
IV. Cooperation of government agencies and international organizations
● The Russian Elites, Proxies, and Oligarchs (REPO) Task Force
● Extensive existing frameworks: The Global Focal Points Network on Asset Recovery, coordinated by INTERPOL; the Stolen Asset Recovery Initiative (StAR); Egmont Group; the Camden Assets Recovery Inter-Agency Network (“CARIN”).
● Cooperation among EU member states
● Matt Moses, Partner, ORRICK
● Helene Dewing-Kapur, Europe Head of Sanctions, HSBC
● Amber Vitale, Managing Director – Financial Services, FTI CONSULTING
● Vincent Affourtit, Partner, HOUTHOFF
● Klaus Wiedner, Director Financial Stability, Sanctions & Enforcement, DG FISMA EUROPEAN COMMISSION (TBC)
10:00 – 11:00 AM EDT | 16:00h – 17:00h CET
EACCNY Members: Free
EACCNY non-Members: Free