In the latest edition of our Sanctions Watch weekly digest, we present significant updates on sanction watchlists and regulatory developments.

The United States Department of State published the “Implementation Plan for the Strategy on Countering Corruption” this week. The plan outlines the Department’s activities currently underway or expected to implement the Strategy from 2023-2025. These activities include using sanctions authorities and visa restrictions, as well as engaging with intelligence, law enforcement, and international partners to develop sanctions programs.

The Financial Crimes Enforcement Network (FinCEN) released a report on the Financial Trend Analysis of suspicious transactions that highlight potential links between Russia and global trade partners such as China, Hong Kong, Turkey, and the UAE. These transactions may potentially involve items of particular sensitivity.

In Europe, the European Commission has issued comprehensive guidance in the EU Guidance section, addressing the prevention of Russia sanctions circumvention through strategic risk assessment, stakeholder practices, diversion prevention, banking and finance vigilance, and the identification of circumvention red flags.

The United Arab Emirates (UAE) Executive Office for Control and Non-Proliferation has issued guidance featuring red flags for terrorist financing and proliferation financing, covering activities like rapid ATM cash withdrawals near sanctioned borders, virtual asset exchanges in sanctioned areas, transactions involving embargoed goods, and vessels docking at high-risk ports in sanctioned nations.