Negin Ajam
Senior AML Legal Expert
Advanced LL.M. in European and International Human Rights Law
Published articles
The imposition of sanctions on Russia has evolved significantly since the first measures were introduced in 2014, after Russian forces annexed Crimea. At that time, the European Union's response was cautious.
Identifying suspicious activities is a cornerstone of combating money laundering, helping Obliged Entities (OEs) detect and deter fraud and other illicit activities. To this end, OEs must closely monitor high-risk criteria to flag transactions or behaviours that deviate from standard patterns. All red flags should be investigated to determine whether they represent legitimate transactions or warrant further scrutiny.
The proliferation of unilateral and secondary sanctions has led to a concerning trend of overcompliance by businesses, particularly banks and financial institutions. Overcompliance refers to excessively restrictive practices that go beyond the requirements of sanctions regulations.