Schemes and Subversion: How Bad Actors and Foreign Governments Undermine and Evade Sanctions Regimes

Chairman Himes, Ranking Member Barr, and distinguished members of the committee, I am honored to appear before you today to discuss how bad actors and foreign governments undermine and evade sanctions regimes.

I come before this committee as an economic sanctions and compliance professional, having worked at the U.S. Department of the Treasury and advised financial institutions, corporations, humanitarian organizations, and individuals on ensuring they operate in compliance with U.S., EU, and UN sanctions obligations. I have spent countless hours studying, assessing, and countering methods by which illicit actors try to evade our sanctions.

My testimony today will focus on the importance of countering sanctions evasion, which can undermine our successful use of these powerful tools of economic statecraft. Indeed, without effective efforts to counter evasion, our sanctions programs are less impactful, less likely to achieve U.S. national security objectives, and more likely to cause pain to innocents. I will provide an overview of the different types of sanctions used by the United States and then discuss the importance of countering efforts to evade these programs. I will then focus on certain key areas of sanctions evasion we have observed in the last few years, including how illicit actors have tried to circumvent our prohibitions, as well as future areas to watch. Finally, I will turn to how best to counter sanctions evasion, and what Congress, the administration, and the private sector can do to detect and disrupt evasion activity.

Read the full written testimony here.