Framing and detecting EU targeted sanctions. Evasion and Circumvention Techniques by Russian individuals and entities

• In Event: ECACTJ Panel 3. Conflict, crime, and international involvement: understanding and documenting crimes in war-time Ukraine

Abstract

The enforcement of EU restrictive measures is deeply fragmented since it mainly relies on national competent authorities often lacking adequate operational capabilities. The activities related to the asset tracing are currently very limited, as well as the start of joint investigations or criminal prosecutions. This paper will discuss the preliminary results of a large-scale analysis of the firms controlled by Russian sanctioned entities in European countries. In particular it will shed light of (a) where (in which countries, regions and economic sectors) these firms operate; (b) how these firms are controlled, through which corporate ownership structures, holding companies and intermediary jurisdictions; (c) whether their ownership and governance schemes can suggest money laundering, financial crime and sanction circumvention practices. The analysis is carried out under the project KLEPTOTRACE, co-funded by European Commission, ISF police.

Authors

• Giovanni Nicolazzo, Catholic University of the Sacred Heart, Milan

• Matteo Anastasio, Transcrime – Università Cattolica del Sacro Cuore

• Michele Riccardi, Transcrime - Università Cattolica del Sacro Cuore

• Carlotta Carbone, Catholic University of the Sacred Heart, Milan