Breaking the Chains of Evasion: Europe’s Fight against Sanctions Enablers

Sanctions are a key tool in Europe’s arsenal against aggression, corruption, and kleptocracy. Since February 2022, sanctions have been instrumental in isolating Vladimir Putin’s regime, targeting his cronies, and depleting the Kremlin’s war chest. Yet, as sanctions regimes have tightened, a shadow industry has emerged to undermine them: professional enablers who help sanctioned entities evade restrictions, hide wealth, and sustain destructive activities.

These enablers—lawyers, accountants, real estate agents, financial consultants, and trust service providers—cloak their illicit activities behind the guise of professional respectability. They exploit regulatory loopholes, lax oversight, and jurisdictional differences across the EU to move billions of euros into hidden accounts, luxury assets, and offshore structures. This must stop.

The Mechanisms of Evasion

Investigative journalism and official reports have exposed how enablers employ sophisticated strategies to facilitate sanctions evasion. Oligarchs and their networks use shell companies, proxies, and opaque trusts to obscure ownership and maintain control over assets. They leverage jurisdiction shopping to exploit regulatory disparities and time lags in sanctions enforcement. The Rotenberg Files, Cyprus Confidential, and other revelations highlight these tactics in disturbing detail.

Enablers do not act in isolation. They operate within networks that rely on weak regulatory oversight and complicity in certain jurisdictions. For example, the widespread use of Cyprus as a hub for Russian wealth underscores the urgent need for EU-wide regulatory harmonization. Allowing such practices to persist undermines our credibility and weakens the collective impact of sanctions.

Europe’s Gaps and Challenges

The EU has made strides in sanctioning individuals and freezing assets, but it lags behind the United States and the UK in addressing the enablers of evasion. While the U.S. Department of Justice’s Task Force KleptoCapture aggressively targets professional networks aiding Russian oligarchs, Europe’s enforcement remains patchy and inconsistent.

A major obstacle is the lack of harmonized enforcement mechanisms across Member States. Some jurisdictions are stringent, while others remain lenient, creating opportunities for arbitrage. For instance, the EU’s beneficial ownership transparency rules are undermined by weak implementation in certain Member States. Without robust action, Europe risks becoming a safe haven for kleptocratic wealth.

What Needs to Change

Europe must adopt a comprehensive, aggressive approach to disable the enablers of sanctions evasion. The following steps are critical:

1. Criminalize Enabling Activities: in November 2022, the European Council took a significant step by adding sanctions evasion to the list of EU crimes. A directive proposed by the European Commission to harmonize definitions of sanctions evasion and establish minimum penalties across Member States followed this move. The European Parliament’s proposal to make sanctions evasion an EU crime builds on these efforts and is a step in the right direction. However, we must go further by explicitly targeting the enablers who design and execute these schemes. Legal and financial professionals who knowingly assist sanctioned individuals must face serious criminal penalties, including disbarment, asset confiscation, and imprisonment.
2. Harmonize Enforcement Across Member States: The EU’s sanctions regime is only as strong as its weakest link. We need uniform rules and coordinated enforcement to close jurisdictional gaps. Establishing a central EU sanctions enforcement body, similar to the proposed European Anti-Money Laundering Authority, would ensure consistent application across all Member States.
3. Enhance Beneficial Ownership Transparency: Publicly accessible and verified beneficial ownership registries must be a cornerstone of our fight against evasion. Member States must fully implement these registries and provide investigative authorities with the tools to trace assets quickly and effectively.
4. Target Jurisdictions of Concern: Countries and territories that consistently facilitate sanctions evasion must face consequences. The EU should designate such jurisdictions as “enablers of sanctions evasion” and impose restrictions on their financial transactions and access to European markets.
5. Introduce Robust Due Diligence Requirements: Extending anti-money laundering obligations to non-financial sectors, such as law firms, trust service providers, and real estate agents, is long overdue. These actors must be required to perform enhanced due diligence on their clients and report suspicious activities.
6. Combat ‘Golden Passports’ and ‘Visa Shopping’: Many sanctioned individuals have exploited citizenship-by-investment schemes to access European jurisdictions. These programs must be eliminated or subject to strict oversight to prevent abuse.
7. Empower Journalists and Civil Society: Investigative journalism has been critical in exposing sanctions evasion. Governments must protect journalists from legal harassment, including SLAPP lawsuits, and provide channels for civil society to contribute to enforcement efforts.

Leveraging Europe’s Foreign Policy Leadership

Europe’s ability to lead on sanctions enforcement is not only a test of its commitment to Ukraine but also a broader signal of its geopolitical resolve. During my years as Chair of the Foreign Affairs Committee of the Saeima (Latvian Parliament) and now as an MEP I have engaged with policymakers, civil society, and international organizations to strengthen the EU’s response to Russia’s aggression. Drawing from these engagements, it is clear that sanctions can only be effective when complemented by robust enforcement mechanisms that leave no room for circumvention.

Sanctions enforcement is not a theoretical exercise—it is a practical tool that directly affects the Kremlin’s ability to fund its war machine. For example, effective coordination among allies has already demonstrated success in freezing billions in assets belonging to sanctioned individuals. However, more can and must be done, especially when professional enablers continue to operate with impunity across multiple jurisdictions.

Europe must also align more closely with partners like the U.S. and the UK, leveraging the expertise of initiatives like Task Force KleptoCapture and the REPO Taskforce. Such partnerships amplify our collective strength and demonstrate to authoritarian regimes that democratic nations stand united against corruption and aggression.

Putin’s oligarchs and enablers cannot operate without access to our systems. They exploit the very principles of transparency and rule of law that underpin our democracies. To protect these values, Europe must act decisively to close the loopholes that allow evasion to thrive.

The stakes are high. Russia’s war in Ukraine is not just a test of our resolve to defend sovereignty and democracy; it is a litmus test for the strength of our sanctions regime. By targeting the enablers, we can ensure that sanctions bite where they should and send a clear message: Europe is no place for kleptocrats or their collaborators.