Sanctions Evasion and Circumvention

Lawyers should remain alert to attempts to conceal sanctions connections or circumvent sanctions restrictions.

Potential indicators may include:

• opaque ownership structures;
• frequent changes in ownership;
• unexplained intermediaries;
• unusual payment routes;
• use of multiple jurisdictions without a clear rationale;
• sudden changes in transaction structure;
• inconsistent explanations regarding ownership or funding;
• attempts to avoid identifying beneficial owners; and
• reluctance to provide information about the source or destination of funds or assets.

The presence of such factors does not necessarily indicate wrongdoing. However, they should be considered carefully and reflected within the Client and Matter Risk Assessment.