U4 HELDESK ANSWER 2024: 32 - The circumvention of sanctions: Lessons for anti-corruption regimes

The circumvention of sanctions: lessons for anti-corruption regimes 7 While ostensibly targeting the misappropriation of state assets, the EU introduced standalone, country specific regimes targeting of suspected corrupt officials in the aftermath of the political revolutions in Tunisia, Ukraine and Egypt during the 2010s (Portela 2019). [...] The circumvention of sanctions: lessons for anti-corruption regimes 10 State of affairs This section describes the de jure measures built into sanction regimes to address and prevent circumvention and then describes the de facto situation regarding the implementation of these measures, within the limits of available data. [...] Indicators of anomalies included the complexity of the firms’ corporate structures, such as the number of layers of intermediate entities present, the high use of legal arrangements such as trusts and the existence of entities or beneficial owners within the corporate structure who were featured in leaks such as the Panama Papers or were linked to jurisdictions grey listed by FATF (Transcrime 2022. [...] The circumvention of sanctions: lessons for anti-corruption regimes 16 The European Commission argued golden passports impede the effectiveness of border controls and the enforcement of sanctions since it becomes harder to detect the identities of DPs; for example, under some of these schemes, people can even change their names and identities upon obtaining double citizenship (Jolly and O’Carroll. [...] Supporting the private sector is an important element of other sanctions regimes; for example, the FATF recommends that, in terms of ensuring compliance with recommendation 19 on the implementation of targeted financial sanctions against terrorism and its financing, ‘countries need to be aware of the impact compliance with these laws has on their business activities, and seek to minimise the costs.