Suspicious activity reports recently filed with the U.S. government show nearly $1 billion worth of transactions over the last year may have had ties to Russia-related export control evasion, the Financial Crimes Enforcement Network said in a new report analyzing SAR trend data. The report -- issued as part of a joint effort between FinCen and the Bureau of Industry and Security to collect more leads for export enforcement agents -- highlights several evasion trends being reported by banks and other financial institutions, including what types of goods are most commonly being sought by sanctions evaders and which foreign countries those transactions most frequently involve.
Andrew Adams, former acting deputy assistant attorney general for DOJ's National Security Division, has joined Steptoe & Johnson as a partner in the Investigations and White-Collar Defense Practice in New York, the firm announced. Adams worked as the first director of Task Force KleptoCapture -- the interagency group tasked with enforcing U.S. sanctions on Russia in wake of the invasion of Ukraine. At DOJ, he also oversaw efforts pertaining to economic sanctions, export controls and cyber offenses tied to nation-state actors, the firm said.
The European Commission released a general guidance document on implementing due diligence practices to halt the circumvention of the sanctions on Russia. The guidance includes risk assessment of possible sanctions circumvention, due diligence best practices, circumvention red flags related to business partners and buyers, and EU sanctions whistleblower tools. The due diligence best practices section addresses the stakeholder and transaction levels and the level of the goods themselves.
The EU General Court this week upheld one application for delisting under the Russia sanctions regime and rejected six others. The court removed former Ozon CEO Aleksandr Shulgin from the sanctions list, saying his relisting was not justified. The court said that given Shulgin had resigned his post and the European Council had not looked in why listing was still proper, he was not properly sanctioned, according to an unofficial translation.
The EU added six individuals to its Global Sanctions Regime for their role in perpetuating "serious human rights violations" in Russia and Ukraine, the European Council announced. The individuals include prosecutors and judges in Russia-occupied Crimea who participated in the "politically motivated court proceedings" against journalist Vladyslav Yesypenko. The council also sanctioned two members of the Russian Federal Security Service who either tortured Yesypenko or investigated him.
Treasury Secretary Janet Yellen said despite the fact that Russia has managed to use ships and insurance companies from countries that didn't agree to a price cap on Russian oil sales, the sanction is working.
The U.K.'s Financial Conduct Authority released a review of the country's sanctions systems on Sept. 6, finding firms that carried out risk exposure assessment ahead of Russia's invasion used proper practices. The review also found many firms needing better governance and oversight, and said certain companies were "too reliant on third-party" sanctions compliance tools and didn't align their practices with U.K. sanctions rules. The review spotted various backlogs regarding sanctions screening alerts and said some firms didn't have "adequate internal expertise," the report said.
The U.K. added 11 Russians to its sanctions regime related to cyberattacks against the country. In a Sept. 7 notice, the Office of Financial Sanctions Implementation imposed restrictions against the individuals for contributing to ransomware attacks that threaten the U.K. and "cause economic loss to, or prejudice the commercial interests of, those companies affected by the activity."
The Bureau of Industry and Security issued a temporary denial order last week against three people and four companies for their involvement in a scheme to illegally procure more than $225,000 worth of U.S. electronics components for Russia’s military. One of the individuals, Russian-German national Arthur Petrov, was arrested Aug. 26 in Cyprus and charged by DOJ with violating export controls and smuggling controlled goods from the U.S.
The Office of Foreign Assets Control this week sanctioned two people and one entity involved in helping North Korea’s weapons and missiles program earn revenue. The designations target Jon Jin Yong and Sergey Mikhaylovich Kozlov, who coordinated work for North Korean construction workers in Russia and procured items used in the ship-building industry. OFAC also sanctioned Intellekt, a company that Yong used in a Moscow-based construction project, for being owned or controlled by Kozlov.