Restrictive measures : the challenges in front of the EU : report on schemes employed to circumvent sanctions

Abstract

This report, carried out by Transcrime – Università Cattolica del Sacro Cuore, explores the results of the first comprehensive analysis of the recurrent schemes used by sanctioned entities to evade international sanctions, with the aim of reducing the current gaps in sanctions enforcement thanks to a deeper understanding of the phenomenon. After a general assessment of the nature and effectiveness of sanctions (a more detailed review on this topic is available here) and of shortcomings in the enforcement framework, the report focuses on: - Most violated sanctions by category, region, goods, and assets. - The role of facilitators, corporate vehicles, and satellite jurisdictions. - Recurrent evasion schemes and transactions. - Policy implications and risk indicators.This document provides a comprehensive resource for public and private sector stakeholders for both investigation and due diligence purposes, and enabled the development of an advanced tool for assessing high-risk entities and for tracing and re-covering illicit assets, which is now made available to interested EU competent authorities for the purpose of tracing criminal assets and sanction evasion schemes.