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US mentions Turkey among possible routes for Russia to evade sanctions

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The US government in a compliance note listed Turkey as being among possible “transshipment points” used to evade sanctions and export controls and illegally redirect restricted items to Russia or Belarus, Voice of America’s (VOA) Turkish service reported on Friday.

Over the year following Russia’s invasion of Ukraine, the US government’s Department of the Treasury’s Office of Foreign Assets Control (OFAC) and the Department of Commerce’s Bureau of Industry and Security (BIS), along with international partners and allies, have imposed sanctions and export controls in an effort to degrade Russia’s ability to wage its war.

The joint compliance note, issued by the Departments of Justice, Commerce and Treasury and released on Thursday, aims to “inform the private sector about enforcement trends and provide guidance to the business community on compliance with US sanctions and export laws.”

In the note the three agencies highlighted several tactics to assist the private sector in identifying warning signs regarding the methods used to try to evade Russia-related sanctions and export controls, such as the use of third-party intermediaries or transshipment points to circumvent restrictions.

They said such “red flags” as routing purchases through certain transshipment points commonly used to illegally redirect restricted items to Russia or Belarus, including China, Armenia, Turkey and Uzbekistan, can indicate that a third-party intermediary may be engaged in efforts to evade sanctions or export controls.

Among the other signs listed were the use of corporate vehicles to obscure ownership, source of funds or countries involved; the use of shell companies to conduct international wire transfers; last-minute changes to shipping instructions that appear contrary to customer history or business practices; and transactions involving a change in shipments or payments that were previously scheduled for Russia or Belarus.

In the conclusion of the note, multinational companies are urged to be “vigilant” in their compliance efforts and to be on the lookout for possible attempts to evade US laws.

“The U.S. government has a variety of tools to crack down on evasion efforts, and … it will not hesitate to pursue criminal prosecutions, administrative enforcement actions or additional designations where the circumstances so warrant,” the note said.

The top sanctions official from the US Treasury Department, Brian Nelson, visited Turkey in early February and warned businesses that they could lose access to the US market if they engage in business with entities that are subject to US sanctions.

“… We are working to stop and prevent Russian efforts to circumvent international sanctions and financial controls in dozens of countries, including Türkiye. … In engaging with sanctioned Russian entities, Turkish businesses and banks could put themselves at risk of sanctions and a potential loss of access to G7 markets and correspondent relationships,” Nelson said in a speech in Turkey.

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