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Sanctions Evasion Methods Under Scrutiny
As global efforts to combat financial crime and sanctions evasion continue, regulatory bodies are urging vigilance against a range of tactics used by individuals and entities to circumvent restrictions.
Common Methods Used for Sanctions Evasion
According to recent data, some common methods used to evade sanctions include:
- Routing purchases through jurisdictions known for facilitating transactions with restricted countries or entities
- Using shell or front companies based in high-risk regions to conceal ownership and control
- Falsifying information on transactions to disguise the true nature of financial activities
- Utilizing virtual currencies and other alternative financial channels to conceal illicit funds
Reporting Suspicious Transactions
As of August 19, 2024, all reporting entities are required to submit a suspicious transaction report to FINTRAC if they have reasonable grounds to suspect that a financial transaction is related to money laundering, terrorist financing, or sanctions evasion. These reports are critical in helping FINTRAC develop and disseminate financial intelligence.
Indicators of Sanctions Evasion
Some key indicators of sanctions evasion activity include:
- Transactions initiated from or sent to IP addresses in sanctioned jurisdictions
- Connections to virtual currency exchanges or services located in high-risk regions
- Use of unlicensed brokers to off-ramp cryptocurrency to unknown third parties
- Concealment of ownership, control, and structure of entities involved in transactions
Contact FINTRAC
For guidance on submitting suspicious transaction reports and for more information on sanctions evasion methods, contact FINTRAC at:
Email: guidelines-lignesdirectrices@fintrac-canafe.gc.ca (include Special Bulletin FINTRAC-2024-SB002 in the subject line) Telephone: 1-866-346-8722 (toll free) Facsimile: 613-943-7931 Mail: FINTRAC, 24th Floor, 234 Laurier Avenue West, Ottawa ON, K1P 1H7, Canada
Special Bulletin
FINTRAC Special Bulletins provide information on new, emerging, and topical methods of money laundering, terrorist activity financing, the financing of threats to the security of Canada, and sanctions evasion. However, these Bulletins should not be considered legal advice. Please refer to the Proceeds of Crime (Money Laundering) and Terrorist Financing Act and its associated Regulations for full description of reporting entities’ obligations.
Date Modified: 2024-06-25
(c) His Majesty the King in Right of Canada, 2024. Cat. No. FD4-36/2024E-PDF ISBN 978-0-660-71589-6