The US authorities considered suspicious transactions carried out by delivery through Uzbekistan, RBC has reported with reference to a list of recommendations compiled jointly by the Ministries of Industry, Justice and Finance of the United States.
In the US, manufacturers, distributors, resellers and cargo carriers were urged to pay attention to suspicious transactions, emphasizing that they have all the capabilities to check for signs of violations of the sanctions regime.
Among the signs that may signal the circumvention of Western sanctions, the US authorities distinguish the following:
- Claiming that shell companies located in third countries were intermediaries or end users; in one case, DOJ alleges that only one of the five intermediary parties had any visible signage and consisted of an empty room in a strip mall;
- Claiming that certain items would be used by entities engaged in activities subject to less stringent oversight; on at least one occasion, a defendant allegedly claimed that an item would be used by Russian space program entities, when in fact the item was suitable for military aircraft or missile systems only;
- Dividing shipments of controlled items into multiple, smaller shipments to try to avoid law enforcement detection;
- Using aliases for the identities of the intermediaries and end users;
- Transferring funds from shell companies in foreign jurisdictions into U.S. bank accounts and quickly forwarding or distributing funds to obfuscate the audit trail or the foreign source of the money22;
- Making false or misleading statements on shipping forms, including underestimating the purchase price of merchandise by more than five times the actual amount;
- Claiming to do business not on behalf of a restricted end user but rather on behalf of a U.S.-based shell company.
The EU has also become aware of the increased attention to compliance with the sanctions imposed on Russia. The EU's Special Representative for sanctions, David O'Sullivan, suspected that the states bordering Russia were helping it to circumvent European sanctions.
In early February 2023, the US Treasury imposed sanctions against a citizen of Uzbekistan, Max Piflaks, for facilitating the circumvention of sanctions by the Russian military industry. During his visit to Tashkent, US Secretary of State Anthony Blinken noted that Washington was closely monitoring compliance with sanctions by Central Asian countries.
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