Daily Compliance Brief — Renewed Focus on Russia Sanctions Evasion Controls

January 16, 2026

Signal

Over the past 24 hours, public statements and supervisory communications from US and UK authorities reinforced expectations that financial institutions actively address ongoing Russia-related sanctions evasion risks. Regulators emphasised continued misuse of third-country intermediaries, complex ownership structures, and trade-based mechanisms to circumvent existing restrictions.

Authorities reiterated that enforcement focus is shifting toward institutions that fail to adapt controls to evolving evasion typologies, even where formal sanctions screening is in place. Particular attention was drawn to transaction chains involving non-sanctioned jurisdictions with elevated re-export and transshipment risk, as well as to insufficient scrutiny of beneficial ownership and trade documentation.

Why it matters

For compliance teams, this reinforces the need to calibrate sanctions monitoring beyond static name screening, incorporating risk indicators linked to trade flows, intermediary jurisdictions, and changes in customer behaviour. Weaknesses in understanding transaction purpose or ownership structures may be treated as control failures rather than judgment gaps.

Institutions should reassess sanctions risk assessments, escalation thresholds, and cross-functional coordination between sanctions, trade finance, and AML teams. Persistent regulatory attention to evasion methods increases exposure to supervisory findings where controls do not reflect current risk patterns, even in the absence of direct dealings with sanctioned parties.