In June 2025, the Financial Action Task Force (FATF) released a report titled “Complex Proliferation Financing and Sanctions Evasion Schemes”. This document outlines the increasingly sophisticated methods used by actors, especially those linked to weapons of mass destruction (WMD) programs, to circumvent international sanctions and continue illicit financial activity.
The FATF’s analysis is based on case studies submitted by member states, and it identifies common patterns, vulnerabilities, and red flags. The report aims to help financial institutions, governments, and regulators better detect and disrupt such activities.
Key findings:
- Use of front and shell companies: Illicit networks often establish layers of opaque ownership across multiple jurisdictions to obscure the true beneficiaries.
- Trade-based money laundering (TBML): Fraudulent invoicing and complex shipping routes are used to move goods and funds covertly.
- Cryptoassets: Digital assets are increasingly leveraged for anonymity, especially in regions with weak oversight.
- Third-country involvement: Sanctioned countries exploit non-compliant or under-regulated jurisdictions as intermediaries.
- Professional enablers: Lawyers, accountants, and service providers are sometimes unknowingly – or knowingly – used to establish and maintain the structures needed for evasion.
Recommendations
FATF urges countries to:
- Strengthen beneficial ownership transparency.
- Enhance screening in trade finance.
- Ensure cryptoasset providers are well-regulated.
Financial institutions should adopt a risk-based approach and remain alert to red flags.
Source: https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Complex-PF-Sanctions-Evasions-Schemes.pdf.coredownload.inline.pdf
aml.plus team
English 
Latvian 
Russian 
Greek