Canada’s financial intelligence unit (The Financial Transactions and Reports Analysis Centre of Canada – FINTRAC) and the financial intelligence units of the Netherlands (FIU-NL), Germany (FIU DE) had received reports about the illegal export of dual-use goods to Russian end-users in violation of current sanctions.
After that, FINTRAC published a recommendation to support entities in recognizing cases that clients are trying to skirt financial sanction:
• The goods are shipped to countries bordering the Russian Federation.
• Payment is handled by a third party not involved in the trade transaction.
• The goods are shipped through the sanctioned jurisdiction (e.g. by using a fictive end-user in another country).
• The goods are shipped to countries and territories such as Türkiye, China, Hong Kong, and the United Arab Emirates. These countries and territories are known to be used as re-export conduits for the Russian Federation.
• Invoices are backdated to suggest the trade was part of older contracts for which restriction-exemptions can requested.
The full text of the advisory are published in the FINTRAC website.
