Policy Director Lakshmi Kumar testified before the House Financial Services Subcommittee on National Security, International Development, and Monetary Policy for the hearing on “Schemes and Subversion: How Bad Actors and Foreign Governments Undermine and Evade Sanctions Regimes.”
Kumar’s testimony covers schemes utilized by criminal actors and bad governments to evade and undermine the U.S. sanctions regime.
Detecting sanctions evasions is difficult and complex. Actors seeking to evade sanctions exploit existing cracks in U.S. and global anti-money laundering (AML) regulations. The methods of evasion depend heavily on who is being targeted by sanctions.
Kumar’s testimony discusses sectors and industries both in the U.S. and internationally where weak regulatory environments facilitate sanctions evasion. This includes mineral and commodity trade, trade based money laundering, shipping, investment, and real estate, all of which offer various weaknesses that can be exploited to evade sanctions. Improving regulations and oversight in these sectors and strengthening AML infrastructure both in the U.S. and internationally will improve the ability to enforce sanctions.