FATF on Sanctions and Export Controls Evasion

And ways to protect your business against such risks

Alexey Tyurin
June 22, 2025

🚀 FATF just published a report highlighting various sanctions and export controls evasion schemes, including:

💡 Case studies in the typology section show how various parties perpetrate the above.

⚠️ Risk indicators in Annex A highlight customer behavior, transactions and trade activities that may call for greater scrutiny.

🧋 With no silver bullet, any given firm may consider a combination of the following:

Automated sanctions screening systems with integrated sanctions lists and provision of key words for a more targeted search
Negative news screening of associated persons
Enhanced due diligence for persons deemed as high-risk
Ongoing employee training

For more details, you can find the document here.

Below are some other themes that caught my attention this week:

Structuring transactions to violate the US sanctions regime: Former CEO of Unicat Catalyst Technologies, a Texas-based manufacturer, structured transactions to knowingly violate the US sanctions regime on Iran and Venezuela.
Taiwan tightens export controls: Taiwan added Huawei and SMIC to its Entity List. Local firms will be required to obtain gov approval ahead of shipping tech/materials/materials.
Managing funds for sanctioned Russia persons: GVA Capital, a San Francisco VC firm, knowingly managed investments for sanctioned Russian oligarch and his proxies. 50% Rule did not apply. USD 216m fine (statutory maximum).
Stablecoin regulation and the GENIUS Act: the United States senate passed stablecoin legislation. This ensures USD dominance (~97% are USD denominated, as of today).
UK Digital ID: Downing street is exploring proposals for a digital ID card (BritCard app), meant to facilitate “right-to-rent” and “right-to-work” checks.

Feel free to reach out if any comments or questions.

alexey [at] atyurin.com

Thanks for reading!

Alexey