The economic, legal and trade restrictions imposed on Russia in the wake of its full-scale invasion of Ukraine represent arguably the most sweeping sanctions regime ever implemented. The UK has played a leading role in this international response, sanctioning over 2,000 individuals and entities linked to the Kremlin’s war machine and freezing more than £25 billion of Russian assets. Yet sanctions are only as effective as their enforcement and, in an increasingly globalised and digitised economy, enforcement is complex. Professional enablers register shell companies in offshore jurisdictions and obscure ownership through the use of opaque investment vehicles and cryptocurrencies. Organised crime networks provide covert money laundering services to sanctioned individuals and a shadow fleet of illicit oil tankers maintains Russia’s oil exports in violation of sanctions. In this ever-shifting cat-and-mouse game, enforcement agencies often find themselves in the dark, a challenge compounded by their lack of resources. The UK Office of Financial Sanctions Implementation (OFSI) has been taking an increasingly proactive approach to sanctions enforcement, including through collaboration with sanctions authorities in other countries. But where the UK lags behind its US and EU partners is in acknowledging that sometimes the most powerful force multiplier is an insider – someone who can turn on the light.
Rethinking Whistleblowing in the Age of Global Sanctions | Royal United Services Institute
