The Council of Europe invites business operators to an online training session regarding the effective implementation of the sanctions/restrictive measures regime, on 26 June 2025, 9 am (CEST) – Registration deadline: 19 June 2025
Trade-based sanction evasion tactics: review of red flags, tactics and typologies of illicit actors used to move assets and funds through trade activity linked to Russia.
This session of the Council of Europe will focus upon the different tactics to move assets and funds through trade activity in breach of sanctions imposed on Russia, ways to resolve complexities and challenges in identifying such illicit activity to distinguish between “normal” and “unusual” trade arrangements. Using real case examples, this session will also consider “red flags”, tactics and typologies of illicit actors used to move assets and funds through trade activity linked to Russia aggression against Ukraine.
Council of Europe registration form available through the QR code below or the following link: https://forms.office.com/e/qvSC0AywpY.
Agenda of the online training session
09:00 – 09:30 (CEST): Registration of participants
09:30 – 09:45: Introductory remarks
Economic Crime and Cooperation Division (ECCD), Council of Europe
Secretariat-General, Structural Reform and Investment Task Force (SG REFORM), European Commission
09:45 – 11:15: Part 1 – Scope of Trade-Based Activity Linked to Sanction Circumvention
- Nature of trade activities
- Financial institutions and intermediaries involved
- General categories of tactics employed to undertake trade-based sanction evasion activity
- Movement of funds and value through illicit trade-based activity
Council of Europe Expert
Discussion and Q&A
Moderated by ECCD, Council of Europe
11:15 – 11:40: Break
11:40 – 13:00: Part 2 – Measures to Detect and Prevent Abuse of Trade-Based Activity and Lessons learnt from Past Control Failures
- Due diligence and knowledge of trade-based activities
- Distinctions between “normal” and “unusual” trade arrangements
- Examples of control failures and deficiencies
- Examples of compliance control failures and lessons learnt
Council of Europe Expert
Discussion and Q&A
Moderated by ECCD, Council of Europe