FATF consultation on complex proliferation financing and sanctions evasion schemes

A&O Shearman
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A&O Shearman

The Financial Action Task Force (FATF) has published a consultation aimed at improving country and private sector understanding of current proliferation financing (PF) risks. This study will detail the evasion techniques used by those evading the targeted financial sanctions detailed in Recommendation 7 of the FATF Standards, as well as other national and supranational sanctions that are not covered by the FATF Standards. The resulting report will focus on providing a comprehensive up-to-date understanding of typologies in complex sanctions evasion schemes relevant to PF and identifying enforcement challenges and best practices, which helps to inform countries' PF risk assessment and risk mitigation.

The questions posed by the FATF include: (i) which unique products or services are most vulnerable to exploitation by sanctions evaders and PF actors; (ii) how risks related to vulnerable products or services and/or high-risk countries for sanctions evasion and/or PF activity are managed; (iii) measures (such as setting suspicious transaction report rules) that effectively detect potential sanctions evasion activity; (iv) best practices for information sharing with the public and/or private sectors; and (v) what public information the FATF can provide to assist the private sector and others in mitigating PF risk.

The deadline for responses is 21 March.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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