Aziz Rahman outlines the authorities’ state of alert regarding sanctions

With the National Economic Crime Centre and the Office of Financial Sanctions Implementation having issued a red alert regarding sanctions evasion, Law360 asked Aziz Rahman for his assessment.

Aziz explained that the alert was a clear indicator that regulators are aware of the techniques that could be used by those who are looking to avoid the impact of sanctions that have been imposed on them.

He said: "In such a fast-moving, rapidly-changing environment, the relevant agencies are showing that they recognise the potential for chicanery by those looking to bypass the effect of sanctions. The agencies, it seems, are eager to prevent such manoeuvring.’’

The alert, which is a 15-page document, was issued by the agencies in conjunction with the Joint Money Laundering Intelligence Taskforce. It was prompted by sanctions being imposed after Russia’s invasion of Ukraine.

The alert makes it clear that designated persons and entities — those who are subject to sanctions — will be attempting to move assets and money to places where sanctions are not in place, such as the United Arab Emirates, China and India. They will also, it warns, look to use alternative payment methods, such as cryptoassets, to avoid being affected by sanctions.

Recommendations for regulated companies are detailed in the alert. It emphasises that financial services, legal and accounting firms need to scrutinise transactions and assess complicated corporate structures when conducting due diligence on clients deemed to be high risk.

Aziz's comments can be read on Law360. (Subscription required)