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
Shadow fleet sanctions evasion and avoidance network
On 02 July 2025, UK authorities published a 'Red Alert' notice on the shadow fleet sanctions evasion and avoidance network.
The notice details how Russian oil trading companies are utilising a complex network of companies to evade sanctions whilst accessing Western finance and professional services in order to continue to fund the Russian state.
red flag indicators include:
companies with limited trading history very quickly trading large volumes of oil
limited information on ownership, directors or beneficiaries
multiple transfers between obscure companies
companies registered or operating in known jurisdictions of high risk, including those where shadow fleet entities are known to operate
The companies often have a limited online presence with no company website or contact information. If a website does exist, generally it will contain generic stock photos, and no details on the individuals operating the company.
Find full details in the Red ALERT: shadow fleet sanctions evasion and avoidance network.
FATF report: Complex proliferation financing and sanctions evasion schemes
On 20 June 2025, the Financial Action Task Force ('FATF') published a new report highlighting that significant vulnerabilities remain across the global financial system in countering the financing of weapons of mass destruction ('WMD').
Based on submissions from across the FATF global network, the report identifies four major typologies used in sanctions evasion:
use of intermediaries to evade sanctions
obscuring beneficial ownership information (BOI) to access the financial system
using virtual assets and other technologies
exploiting the maritime and shipping sectors
Proliferation financing and sanctions evasion – FATF report highlight gaps in global response
Sanctions circumvention - money laundering, organised crime, bribery and corruption
The Financial Intelligence Unit - Jersey has published a typology report exploring how bribery and corruption are used to facilitate the circumvention of financial sanctions. The report offers support to financial institutions in identifying red flags and strengthening controls against sanctions evasion.
Sanctions circumvention - money laundering, organised crime, bribery and corruption
Green alert - oil price cap evasion
On 08 May 2025 the Financial Intelligence Unit - Jersey issued a green alert detailing methods used to circumvent the Russian oil price cap. These include the manipulation of certificates of origin, the use of complex supply chains, and the deployment of shadow fleets. The alert offers recommendations for industry stakeholders to identify these evasion tactics.
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:
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:
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:
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