Detecting and countering financial and trade sanctions evasion: UK lawyers’ guide to red flags, sector typologies, risk controls and reporting (OFSI/OTSI/HMRC/NCA)
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Practice notes
Sanctions are designed to exert significant impact on the people, entities and regimes at which they are aimed. Consequently, there is an attendant danger that those designated will try to sidestep their effect. Grasping the risks of becoming entangled in sanctions evasion, and the warning signs and red flags to watch for, should be integral to your screening. You need not act as law enforcement, but, given the strict nature of your liability for any breach, you must stay vigilant. This Practice Note outlines risks and indicators of sanctions evasion, along with sound practices and steps to take if you are concerned.
Risks of sanctions evasion
Failing to notice an attempt to circumvent sanctions can put you yourself in breach, eg if you end up handling the funds of, or supplying services or other assistance to, an individual who is designated. It could also frustrate the public policy objective behind imposing the sanctions in the first place—see Practice Note: Understanding the financial sanctions regime. Breach of sanctions is a serious criminal offence and could expose your organisation, or individuals working in it, to criminal penalties. Further guidance is provided on what to do if you are suspicious within this Note...
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Web page updated on 21/05/2026
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