With sanctions becoming an increasingly important tool in ostracising autocratic regimes from western markets, the need for effective enforcement of Anti-Money Laundering (AML) policies is increasing. The global AML regime will be the backbone in detecting evasion of sanctions. This regime has, however, been widely criticised as ineffective. In this brief, Giancarlo Spagnolo and Theo Nyreröd discusses issues with the current AML regime and propose a reward scheme for whistleblowers to enable asset seizures. A powerful feature of their proposal is that it does not rely on the effectiveness of the AML regime.

“Sanctions evasions have a lot of similarities with money laundering”

Before Russia’s invasion of Ukraine, we wrote a FREE Policy brief expressing concerns over the ability of the current Anti Money Laundering (AML) regime to keep money launderers out of the international financial system. In the brief, we concluded that “The ease with which criminals have evaded present detection methods should cause concern about the effectiveness of sanctions”. The issue has now received renewed attention as the current sanctions against Russia will only be effective if it is difficult or costly to circumvent them. Sanctions evasions have a lot of similarities with money laundering, and the methods for detecting both is very similar, such that the proposal we discuss in this brief is applicable to both.

While an initial shock due to unexpected sanctions may generate disruptions, prohibited goods can later be imported/exported through third-party intermediaries in non-sanctioned countries to circumvent the sanctions. False labelling of origin, misinvocing, etc., are likely to occur and may be very difficult to detect. Analogously, sanctioned individuals’ assets may shift hands, and be laundered through shell companies without known beneficial owners.

In this brief, we consider a way to enhance enforcement, as outlined in a recent paper. The approach builds upon the US Kleptocracy Asset Recovery Rewards Program which offers up to $5 million “for information leading to seizure, restraint, or forfeiture of assets linked to foreign government corruption”.

Read the full brief to learn more, click here.


Giancarlo Spagnolo
Professor, the Stockholm Institute of Transition Economics (SITE) at the Stockholm School of Economics.
Email: Giancarlo.Spagnolo@hhs.se

Theo Nyreröd
Doctoral Researcher in Law at Brunel University London.
Email: theo.nyrerod@hotmail.com

Dominick Nilsson


Communication Manager,
Stockholm Institute of Transition Economics (SITE)