Sanctions evasion
Sanctions evasion is the deliberate attempt to circumvent the impact of the sanctions prohibitions in place against any targeted country, group or individual.
Sanctions evasion is prohibited under the
Sanctions and Asset-Freezing (Jersey) Law 2019 (SAFL).
The techniques used to evade sanctions vary depending on the type of sanction imposed. It could involve:
- pre-emptively transferring assets to avoid an asset-freeze
- facilitating the import of prohibited items
- disguising military goods to circumvent an export ban
In every case, the goal is to engage in the prohibited activity while remaining undetected.
Reporting a breach of sanctions in Jersey
You should report any suspected breach of sanctions by completing the sanctions compliance reporting form. Send the completed form to the Minister for External Relations (the ‘Minister’) at
sanctions@gov.je.
Sanctions Compliance Reporting Form
These reporting obligations are in addition to the obligation to report suspicious activities to the Financial Intelligence Unit Jersey.
You can submit a
Suspicious Activity Report (SAR) on the Financial Intelligence Unit Jersey.
Guidance from the JFSC on preventing sanctions evasion
You can find guidance on
sanctions obligations and sanctions evasion techniques on the Jersey Financial Services Commission (JFSC).
This expands on their previously published guidance on Proliferation Financing sanctions evasion techniques.
Sanctions alerts and advisories
Threat assessment report: financial services
On 13 February 2025, the UK’s Office of Financial Sanctions Implementation (OFSI) published a Threat Assessment Report covering Financial Services.
The report identifies:
- key evasion threats
- red flags that businesses should be aware of
- recommendations on how to mitigate the identified risks
OFSI Financial Services Threat Assessment Report on GOV.UK
G7 joint guidance on preventing evasion of export control and sanctions against Russia
On 25 September 2024, the G7 published its first joint guidance for industry on preventing evasion of export control and sanctions against Russia.
The aim of the guidance is to help you:
- identify Russian evasion practices
- comply with GECC controls
This is to prevent the diversion of controlled items to Russia, including through third countries.
Russia Sanctions: G7 issues its first joint guidance on preventing Russian export control and sanctions evasion
Exporting high risk goods
In December 2023, the National Economic Crime Centre (NECC) issued a further Red Alert about exporting high risk goods.
This Red Alert warns businesses that Russia is attempting to circumvent sanctions to purchase restricted goods and services, through intermediary countries.
NECC Red Alert on Exporting High Risk Goods on the National Crime Agency
Gold-based financial and trade sanctions circumvention
In November 2023, the NECC also issued a Red Alert on Gold-based Financial and Trade Sanctions circumvention.
The Red Alert also tackles sanctions circumvention by calling on businesses to report suspicious activity, including any attempts to breach sanctions and providing guidance on how to do so.
NECC Red Alert on Gold-based Financial and Trade Sanctions circumvention on National Crime Agency
Alert to industry: sanctions evasion typologies
In July 2022, the UK's NECC issued an alert to industry about the financial sanctions evasion typologies used by Russian elites and their 'enablers', close associates and professional services firms, to evade sanctions. While some of the information in the report is UK-specific, the vast majority will be relevant to individuals and businesses operating in or from within Jersey.
The report details a range of methods used by Designated Persons (DPs) to evade targeted financial sanctions, including:
- transferring assets to trusted proxies
- moving funds to jurisdictions where sanctions are not in place
In order to move funds, DPs are circumventing usual payment methods such as SWIFT. They are moving towards alternatives and there has been an increasing use of crypto-asset services such as Blockchain.
While some enablers may be criminally complicit with, or wilfully blind to, sanctions evasion, others may be unintentionally involved due to weak controls and a lack of due diligence on high-risk clients.
The report provides useful guidance and recommendations for businesses on how to:
- detect suspicious payments
- prevent the transfer of frozen assets
- avoid becoming an unwitting facilitator of sanctions evasion
Financial Sanctions Evasion Typologies: Russian Elites and Enablers on the National Crime Agency
gov.je