Communiqué

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