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Public Consultation on Complex Proliferation Financing and Sanctions Evasion Schemes Project
The SMB would like to inform subject persons of the following updates from the Financial Action Task Force (FATF):
In order to fully understand to current Proliferation Financing (PF) risks, the FATF is conducting a study that will describe the methods used to prevent the targeted financial sanctions outlined in Recommendation 7, which is mandated by the FATF Standards, as well as other national and supranational sanctions that are not covered by the FATF Standards. The report will help countries assess and mitigate their PF risks by offering a thorough understanding of typologies in intricate sanctions evasion schemes that are relevant to PF, as well as by identifying enforcement challenges and best practices.
Responses to the questions are to be provided by completing the online form by Friday 21st March, 2025 (COB Paris time)
For further information you may refer to the FATF website.
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Preventing Russian Export Control and Sanctions Evasion: Updated Guidance for Industry
Part of the G7 Sub-Working Group on Export Control Enforcement’s coordinated efforts is to provide guidance to industry on preventing the diversion of controlled items to Russia, including through third countries. Their collective aim is to assist industry in identifying Russian evasion practices and complying with GECC controls, thereby protecting their technology from misappropriation, preventing reputational harm, and mitigating liability
risk while supporting the continued success of our export controls and sanctions.This guidance document contains:
- A list of items which pose a heightened risk of being diverted to Russia,
- Updated red flag indicators of potential export control and/or sanctions evasion,
- Best practices for industry to address these red flags, and
- Screening tools and resources to assist with due diligence
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Restrictive Measures Against Russia: The Confiscation of the Entire Proceeds of a Brokering Transaction Covered by the Prohibition on Providing Brokering Services for Military Equipment is Permitted
Romanian aerospace firm Neves 77 Solutions SRL was fined around 6,000 euro for brokering services related to military equipment to a Russian operator. The company collected 3 million euros for providing such services, leading to a confiscation of the brokerage fee. The Court of Justice ruled that it is illegal to offer such services to a Russian operator, even if the equipment was never imported into the EU. The court also noted that EU law allows for automatic seizure of entire sums related to military equipment brokerage services.
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