EU Sanctions Circumvention: Identifying Red Flags and Managing Third-Country Risk

Introduction

Sanctions circumvention — using third-country intermediaries,complex corporate structures, and false documentation to evade sanctions — hasbecome one of the most pressing challenges in EU sanctions enforcement. The EUhas progressively tightened its legal framework to address circumvention,adding 'no re-export to Russia' clauses, expanding due diligence obligations,and targeting third-country entities that facilitate evasion. This advancedcourse equips compliance professionals with the knowledge and tools to identifycircumvention patterns, conduct enhanced due diligence, and manage theescalating enforcement risk.

Who ThisCourse Is For

This course is aimed at senior sanctions compliance officers,trade finance specialists, legal counsel, and export managers at financialinstitutions, trading companies, and logistics providers that facecircumvention risk in their transaction flows. Participants should have a strongworking knowledge of EU sanctions.

WhatYou'll Learn

•      The legal framework for anti-circumvention under EUsanctions Regulations

•      Common circumvention methodologies: transshipment,front companies, and false documentation

•      Key third-country jurisdictions with elevatedcircumvention risk

•      Red flags in trade finance, payments, and logistics

•      Due diligence obligations for transactions withcircumvention indicators

•      The 'no re-export' contractual clause: content,application, and enforcement

•      Regulatory expectations and enforcement trends oncircumvention

CourseStructure

Format: Live onlinesession with Q&A, also available as on-demand recording

Duration: 2 hours

Level: Advanced

Assessment: Noformal assessment — attendance certificate issued on completion

Technical Requirements

This course is compatible with most operating systems andmodern web browsers. Live sessions are delivered via video conferencing.On-demand recordings are accessible via the course platform. A stable internetconnection is recommended. If you experience access issues, please contact yourorganisation's IT department or the course provider.

‍Course Content

1. The Legal Framework forAnti-Circumvention

•      Anti-circumvention provisions in EU sanctionsregulations

•      Prohibition on knowingly and intentionally facilitatingcircumvention

•      The legal concept of evasion: what constitutesprohibited assistance

•      New due diligence obligations introduced in the 11thsanctions package

2. Circumvention Methodologies

•      Transshipment through third countries: key transit hubs

•      Front companies, shell companies, and nomineearrangements

•      False country of origin declarations andmis-description

•      Cryptocurrency and virtual assets as a circumventiontool

3. Red Flags in Practice

•      Red flags in payment flows: unusual routing, currencyswitches, and split payments

•      Trade finance red flags: inconsistent documentation,unusual trade routes

•      Logistics red flags: unusual vessel behaviour and cargomis-declaration

•      Corporate structure red flags: recent incorporation,nominee directors, and complex ownership

4. Enhanced Due Diligence

•      When to apply enhanced due diligence for circumventionrisk

•      Third-country due diligence: assessing risk inhigh-risk jurisdictions

•      Beneficial ownership verification in circumventioncontexts

•      Escalation, approval, and documentation of high-risktransactions

5. Contractual and OperationalMeasures

•      Drafting effective 'no re-export to Russia' clauses

•      End-use certificates and their limitations

•      Supplier and distributor due diligence obligations

•      Case example: a circumvention scheme and the compliancefailure that enabled it

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