Sanctions are a crucial tool for exerting influence internationally yet understanding of the impact of sanctions evasion or avoidance (SEA) and third-country involvement is limited. This report reveals that third countries are more likely to engage in SEA when they have trade and commercial capacity, particularly in professional advisory, financial services, shipping and logistics sectors. Private commercial actors within these sectors, with an economic interest in engaging in SEA may find opportunity to do so.

Dr Liam O’Shea, Olivia Allison, Gonzalo Saiz & Alexia Anna Hack

October 2023

This paper examines the practices used to evade sanctions imposed on Russia after its invasion of Ukraine in 2022, focusing on the import–export operations of Russia, Belarus, Georgia, and Kazakhstan. The research finds that sanctions have not cut supplies to Russia but have instead empowered informal trade networks and intermediaries. Georgia and Kazakhstan have indirectly benefited from the increased transiting trade; however, the impact on the shadow economy and traditional organised crime has been minimal because sanctions-busting is not illegal in these countries.

Dr Erica Marat & Dr Alexander Kupatadze

August 2023

This paper provides an analytical overview of how Russian actors and proxies are using illicit financial flows (IFF) to support Russian foreign policy goals. It shows how Russia has used illicit finance to fund political interference campaigns, promote disinformation, and support military operations outside Russia, including the international activities of the Wagner network. It calls for a holistic approach to tackling the issue by combining effective sanctions with systematic efforts to tackle money-laundering and illicit finance in key financial and logistical hubs, including in the UK and other Western countries.

Professor David Lewis & Dr Tena Prelec

August 2023

This briefing note summarises research that explores alternative asset recovery mechanisms that could help respond to the immediate policy goal surrounding Russian-linked sanctioned assets, and also contribute to strengthening the broader asset recovery framework in the UK for the longer term.

Maria Nizzero

March 2023

Decades of wars, internal conflicts and political instability have driven millions of Afghan families into poverty and increased human suffering and vulnerabilities, eroded community resilience, and amplified human trafficking activities (and in several cases also created new forms of these practices). This chapter first provides a brief overview of the main trafficking forms, and their widespread reach and practices in the Afghan context, both before and after the Taliban’s ­takeover in August 2021. Second, it discusses the potential implications and impact of the new Afghan government, international actors and non-governmental organisations’ policies, intentions and ­perspectives for the multiple humanitarian crises in the country, especially for the development of ways to address human trafficking in particular. I argue for prioritising humanitarian assistance. Stakeholders need to pursue a pragmatic approach to responses and negotiations that puts human lives at its centre, to prevent worsening the humanitarian crises, exacerbating vulnerability to human trafficking, and causing further loss of life and other harms.

Thi Hoang

November 2022

Illicit actors in Afghanistan, including drug traffickers, warlords, terrorist groups, and even former government officials, exploit the country to achieve their own political and economic objectives. This paper provides a historical and contemporary overview of illicit financing activities in Afghanistan. It uses a terrorist financing framework to explain the various mechanisms involved in how illicit actors raise, use, move, store, manage, and obscure their funds. Specific jurisdictions used for illicit finance and global financial vulnerabilities that illicit actors with a nexus to Afghanistan exploit in their financial activities are discussed, outlining the threat-agnostic capabilities that could tackle some of these illicit financial challenges.

Jessica Davis

May 2022

Decades of wars and internal conflicts have driven generations and millions of Afghan families into impoverishment, illiteracy, unemployment, and displacement, rendering them unable to provide for their household members, particularly children. Political instability and conflicts have increased human suffering and vulnerabilities, eroded community resilience, stripped people of legitimate and viable economic options, opportunities, and livelihoods, as well as amplifying (in several cases also creating new forms of) human trafficking activities and practices. Drawing on existing academic and grey literatures, expert interviews and media reports, this paper first provides a brief overview of human trafficking situations, forms, their widespread reach and practices in the Afghan context before and after the Taliban’s takeover in August 2021. Second, it discusses the potential implications and impact of various actors’ policies, intentions and perspectives both on the humanitarian crises in Afghanistan, and on human trafficking in particular.

Thi Hoang

May 2022

The Financial Action Task Force (FATF) focuses on combatting money laundering. In February 2012, it codified its recommendations, ‘FATF Recommendations 2012’, consisting of a framework of measures and international standards to combat money laundering and terrorist financing. Once a country agrees to follow the recommendations, it has to produce its anti-money laundering (AML) framework that FATF can assess. In this paper, we attempt to answer a simple question: is this working? We look at a group of eight countries in Africa and the Middle East that in the 2012– 2020 period have voluntarily agreed to implement these recommendations and test whether suspected illicit financial flows (IFF), measured through the trade-gap methods, decline after the decision to implement FATF recommendations. Our results point to a reduction of the trade gap characterising tax avoidance through import under-invoicing and/or Trade Based Money Laundering (TBML) through export over-invoicing.

Sami Bensassi & Arisyi Fariza Raz

May 2022

This research reviews existing evidence on the use and impact of targeted sanctions to disrupt organised criminal activity. It focuses on two case studies, Colombia and Libya, in differing regions of the world and with different exposure to organised crime-focused sanctions. The research analyses organised crime-related sanctions data, examines the current state of knowledge relating to the implementation and impact of these sanctions, and draws on the two case studies to identify a number of factors that influence the effectiveness of organised crime-focused sanctions. While the research focuses on other jurisdictions with track records of using sanctions to disrupt organised crime, implications for the UK are also explored, with a view to informing UK policy thinking on the potential establishment of an organised crime-focused sanctions regime.

Cathy Heinlein, Sasha Erskine, Elijah Glantz & Tom Keatinge

May 2022