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FATF publishes report on complex proliferation financing and sanctions evasion schemes
01.07.2025.

The Financial Action Task Force (FATF) has published “Complex Proliferation Financing and Sanctions Evasion Schemes”. This report is an essential resource that promotes public and private sector understanding of the threats posed by the proliferation of weapons of mass destruction (WMD), as well as their implications for international security and the stability of the financial system.

The publication analyses methods by which states, state-supported entities, and non-state actors seek to circumvent sanctions and finance WMD proliferation through complex financial and procurement schemes. The document also highlights key vulnerabilities in the financial system and provides practical risk indicators that can help identify such activities in a timely manner.

"The FIU notes that the information included in the FATF report may be particularly useful in assessing the application of European Union sanctions against Russia. We also draw attention to the fact that Russia’s cooperation with the Democratic People’s Republic of Korea is a factor that must be taken into account when assessing proliferation financing (PF) and sanctions evasion risks."

IN BRIEF

  • The current risk environment is characterized by state and non-state actors acquiring and/or sourcing dual-use goods, technologies, and knowledge through procurement networks.
  • The Democratic People’s Republic of Korea is identified as the most significant PF risk source, widely employing cyberattacks and generating revenue through IT workers, a variety of other sectors and illicit activity to evade sanctions and obtain funding for its WMD program.
  • The report identifies examples of sanctions evasion schemes involving Iran and Russia. Although these countries are not subject to UN proliferation-related sanctions and are not included in the FATF’s definition of PF risk, their actions pose significant threats.
  • Emerging technologies and virtual assets play an increasing role in sanctions evasion schemes.

To circumvent sanctions and PF-related export controls, complex schemes are used. Based on information submitted by the FATF Global Network, the report highlights four main typologies:

  1. Enlisting intermediaries to evade sanctions restrictions;
  2. Obscuring beneficial ownership information to access the financial system;
  3. Using virtual assets and other technologies;
  4. The use of maritime and shipping sectors.

The report describes challenges and good practices related to the detection, investigation, and prosecution of PF and sanctions evasion, as well as domestic coordination and cooperation, and international collaboration with regards to PF and sanction evasion.

FATF is an international organisation that sets and monitors standards to prevent money laundering, terrorism and proliferation financing (AML/CFT/CPF).

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