Indicators of Russia-Related Sanctions Evasion

In response to Russia's unprovoked and unjustified military aggression against Ukraine, the European Union (EU), the United States (US) and other public international bodies have imposed restrictive measures (sanctions) against Russia since 23 February 2022.

Experts from the FIU Latvia, the Public Prosecutor's Office, the State Security Service, the Financial and Capital Market Commission, the State Revenue Service and five Latvian credit institutions - “Swedbank” AS, “Luminor Bank” AS Latvian branch, “SEB banka” AS, AS “Citadele banka”, BluOr Bank AS, had cooperated for several months and produced the material:

Indicators of Russia-Related Sanctions Evasion

Cooperation between public and private sector institutions took place using the internationally recognized public-private partnership (PPP) format in the prevention of financial crimes, which is known in Latvian regulatory framework as the "cooperation coordination group".

This is one of the first and most comprehensive materials of its kind. The purpose of the collection of indicators is to promote the creation of a common understanding on the implementation of sanctions, as well as to promote the identification of cases of violation of sanctions and attempts of sanctions evasion, both in the public and private sectors. As a result, it is possible to increase the effectiveness of sanctions by preventing attempts of sanctions evasion and promoting prosecution of sanctions violations.

The FIU reminds that the identification of isolated indicators may not always give rise to reasonable suspicion of violation of sanctions. Indicators cannot be viewed separately from the facts and circumstances characterizing specific transactions or activities.