SIFMANet Yerevan Report

European Sanctions and Illicit Finance Monitoring and Analysis Network (SIFMANet) - Yerevan Report
Irina Mamulashvili and Kinga Redlowska | 2025.05.29
This report synthesises the insights collected during the Yerevan roundtable held to evaluate Armenia’s response to geopolitical pressures, to assess enforcement of sanctions frameworks and examine vulnerabilities in illicit financial flows and electoral financing ahead of the 2026 elections.
Introduction
In April 2025, the Sanctions and Illicit Finance Monitoring and Analysis Network (SIFMANet), led by RUSI’s Centre for Finance and Security (CFS) in partnership with the Democracy Development Foundation (DDF), convened a multistakeholder roundtable in Yerevan, Armenia. The session brought together key representatives from Armenian public institutions, financial authorities, civil society and international partners to assess the country’s response to mounting geopolitical pressures, the enforcement of sanctions frameworks, and the vulnerabilities posed by illicit financial flows and electoral financing ahead of the 2026 parliamentary elections.
The roundtable was supplemented by a series of bilateral engagements and one-on-one consultations with representatives from Armenian commercial banks, the Ministry of Justice, investigative journalists, youth groups, diplomats and international think tanks. These discussions provided further detail and contextual depth. This report integrates insights gathered from all formats of engagement.
As with previous SIFMANet roundtables across the EU and its neighbourhood, the Yerevan meeting offered a platform for candid, off-the-record discussions among senior officials from the Central Bank of Armenia (CBA), the State Revenue Committee, the Ministry of Foreign Affairs, civil society organisations (CSOs), private sector representatives, and compliance professionals. The dialogue was informed by Armenia’s evolving geopolitical situation, including its close historical and economic ties with Russia and Iran, ongoing regional instability, and the increased scrutiny brought about by Western sanctions regimes.
This report synthesises the insights collected during the Yerevan roundtable and associated meetings, highlighting Armenia’s institutional innovations in sanctions compliance, the limitations posed by structural and political challenges, and the role of public–private coordination. Additionally, it identifies emerging risks in political financing, including the potential misuse of cryptocurrency and foreign-linked funding channels. These discussions have important implications not only for Armenia but also for neighbouring jurisdictions seeking to strike a balance between maintaining financial openness and safeguarding national integrity against malign financial influence.
Armenia’s Sanctions Landscape
Geopolitical and Economic Context
Armenia’s geopolitical position presents a unique and multifaceted set of challenges, shaped by its limited open borders, unresolved conflicts with neighbouring countries, and a small, trade-dependent economy. These conditions present an operational challenge in imposing G7 sanctions on Russia. Participants underscored the Armenian government’s proactive stance in harmonising with Western sanctions frameworks (for example, introducing Government Decree 808-N), despite economic dependencies and regional dynamics.
Armenia’s foreign policy is multi-vector and seeks to reconcile relations with global powers and neighbouring countries. The strategy has been strained due to continuous war with Azerbaijan over Nagorno-Karabakh, which has caused long-term displacement and regional instability. In addition, Armenia’s diplomatic relations with Turkey remain frozen due to Turkey’s support for Azerbaijan, and while there have been cautious efforts at dialogue, deep-rooted tensions continue to limit Armenia’s broader diplomatic and geopolitical outreach.
Closely linked to the aftermath of the 2020 Nagorno-Karabakh conflict, Armenia’s relationship with Iran has gone through meaningful change, evolving into a more strategic partnership. Participants highlighted key initiatives strengthening this cooperation, including the construction of the 7.2-km Kajaran tunnel, part of the international North–South Road Corridor, and several other major infrastructure projects. According to a diplomatic representative, while these ties benefit Armenia and Iran, they also align with Russia’s political interests, potentially complicating Armenia’s efforts to deepen cooperation with the West.
These dynamics demonstrate the complexity of Armenia’s foreign relations, particularly in the context of its enduring alliance with Russia – a key strategic partner with ties spanning the military, political, economic and energy sectors. Participants noted that Armenia’s continued membership in regional alliances such as the Eurasian Economic Union (EAEU), the Commonwealth of Independent States, and the Collective Security Treaty Organization highlights the continuing depth of its institutional and geopolitical ties with Moscow.
Russia’s full-scale invasion of Ukraine in 2022 had a significant impact on Armenia’s economic ties with Moscow. Participants indicated that Armenia’s economy witnessed a significant acceleration, expanding by 12.6% in 2022 and sustaining a strong momentum, with 8.3% growth in 2023, before moderating to 5.9% in 2024. During this period, participants also highlighted the considerable expansion of trade with Russia – Armenia’s largest trading partner – which increased nearly fivefold from $2.6 billion in 2021 to $12.4 billion in 2024. It was brought up during the discussion, however, that this rapid growth has sparked apprehensions that Armenia may increasingly serve as a transshipment hub for goods subject to international sanctions.
Amid this rising scrutiny, participants mentioned that there has been a parallel surge in misinformation and disinformation targeting Armenia. Hostile foreign actors have been spreading false narratives, suggesting that Armenia is facilitating the circumvention of international sanctions. A representative from the Ministry of Justice stressed that these claims are unfounded, but they represent a considerable danger to Armenia’s global reputation. If left unchallenged, the representative noted, these claims could deter foreign investment and further complicate the country’s economic outlook.
To counter these challenges, Armenia has taken visible steps to illustrate its dedication to sanctions compliance. This has most prominently been accomplished through its financial sector. Representatives of the CBA suggested that Russia-owned VTB Bank and Iran’s Bank Mellat have been sanctioned. These banks are no longer connected to international networks such as Visa and Mastercard or US dollar transactions, and Armenian banks no longer have correspondent relations with them.
While these actions fulfil formal compliance obligations, participants noted that legacy financial ties, particularly through remittances and cross-border transactions, continue to pose systemic risks. Armenia’s large diaspora in Russia, estimated at over 2.5 million people, is instrumental in sustaining financial flows between the two countries. A representative from the Ministry of Economy acknowledged that although remittances can be processed through a wide range of commercial banks operating in Armenia, other Russia-linked channels – informal, alternative, or non-sanctioned ones – still remain faster and more accessible, making them the preferred option for many in the diaspora. This reliance, however, has increasingly come into tension with Armenia’s sanctions commitments. As a CBA representative explained, Armenia has had to discontinue several widely used services to remain compliant with international obligations. One prominent example is “Unistream”, a Russia-based money transfer platform heavily used by the diaspora, which ceased operations in Armenia following US sanctions. In response to such disruptions, Armenian authorities are now working to identify alternative channels that strike a balance between accessibility and compliance with evolving international standards.
Parallel to Russia-related concerns, Armenia’s increasing economic and trade relations with Iran pose concerns in the West about sanctions compliance. This is especially heightened by a new agreement between the EAEU and Iran. A private sector representative pointed out that the agreement is expected to streamline customs procedures, facilitate expanded trade and support the development of regional infrastructure aligned with member states’ economic interests.
At the same time, Armenia remains committed to adhering to international sanctions frameworks. A representative from the CBA said that the country’s sanctions compliance efforts continue to meet international expectations. Recently, Armenia’s interagency working group reviewed the updated US National Security Presidential Memorandum (NSM-2), which provides guidance on reassessing licences involving Iranian entities. A CBA representative noted that while no violations have been identified within Armenia’s financial sector to date, this has been attributed to proactive derisking measures by Armenian banks, especially since most high-risk Iranian actors are already subject to UN sanctions. Nonetheless, the NSM-2’s broader implications for sectors beyond finance are still being assessed by the Armenian government, who are awaiting further engagement with US authorities to clarify the scope of enforcement and reassessments.
Sanctions compliance becomes increasingly important for Armenia as the country seeks to strengthen its ties with the EU and the US. Participants highlighted several key initiatives that have strengthened Armenia’s relations with the EU, including the Comprehensive and Enhanced Partnership Agreement. They also noted that the Council of the European Union welcomed the European Commission’s decision in 2024 to initiate a visa liberalisation dialogue with Armenia. In early 2025, Armenia took another significant step in its foreign policy by signing a Strategic Partnership Charter with the US.
Despite this political and diplomatic pivot toward the West, participants noted a stark disconnect on the economic front. While Russia continues to dominate Armenia’s foreign direct investments, Western countries have yet to make a significant economic impact. No major projects from the EU or the US have matched the scale of investments from Russia or Iran, which continue to act swiftly in executing their strategies in Armenia. Armenia has made efforts to diversify its investment sources; however, these gaps remain a persistent challenge.
Export Control: The Linchpin of Armenia’s Sanctions Enforcement Model
Armenia’s membership in the EAEU is making it difficult for the country to impose G7 sanctions on Russia. The free movement of goods and services among the EAEU member states provides potential avoidance of sanctions as the sanctioned goods can easily go through Armenia and other EAEU member states. This poses a challenge for Armenia to prevent sanctioned goods from flowing into Russia, reducing the efficacy of the sanctions and bringing into question Armenia’s role in facilitating such trade flows.
Participants emphasised that to address these challenges, sanctions compliance needs to be imposed at various levels in Armenia. They explained how responsibilities are shared among competent institutions. The CBA plays a key role in supervising financial institutions and in implementing compliance with sanctions, particularly in detecting and preventing suspicious financial transactions. The State Revenue Committee is responsible for overseeing the licensing process, and the Ministry of Economy enables the support to business subjects, especially small and medium-sized enterprises, to comply with requirements. The Ministry of Foreign Affairs plays a key role in coordinating policy and diplomatic cooperation with foreign counterparts to ensure Armenia’s compliance with international sanctions frameworks.
To reinforce sanctions enforcement mechanisms, the CBA has also greatly improved its enforcement function. CBA members clarified that, in the absence of binding sanctions law, the bank has adopted internal compliance rules and heightened supervisory control through the use of audits. Risk-based guidance tools in compliance with Office of Foreign Assets Control standards have been distributed to financial institutions, supplementing sanctions screening procedures. The CBA has also strengthened its engagement with correspondent banks to maintain Armenia’s link to the international financial system as derisking pressures remain on the rise.
Attempting to circumvent sanctions is classified as a criminal offence under Armenian law, according to participants. During the discussion, attendees referred to the legal framework and noted that at the core of Armenia’s sanctions compliance framework is the Law on Control of Export and Interstate Transit of Dual-Use Goods and Technologies. This law, along with supporting Government Decree No. 924-N (July 1, 2010) and Government Decree No. 1785-N (December 15, 2011), provides the regulatory basis for Armenia’s sanctions compliance efforts. According to participants, these measures govern the movement of sensitive goods and technologies through Armenia, ensuring the country aligns with international sanctions obligations.
Participants were in consensus in naming two flagship initiatives that are the most important results of Armenia’s sanctions compliance. First, the adoption of Government Decree 808-N in 2023 was widely seen as a milestone in the creation of a more robust compliance system. The decree formalised targeted controls – particularly over dual-use items (Common High Priority List) – within a general strategy of monitoring and controlling exports with potential military applications. Second, Armenia’s establishment of a high-level interagency working group, chaired by the deputy prime minister, was mentioned as an accomplishment for institutional coordination on sanctions implementation. According to an official from the Ministry of Justice, the working group was formed in accordance with a 2023 government decree, with the aim of aligning Armenia more closely with the G7 sanctions regimes.
Participants also pointed to Armenia’s export licensing system as a central component of its sanctions compliance architecture. This regulation requires individuals and entities to obtain prior authorisation for the export of dual-use goods, irrespective of the destination, thereby reinforcing Armenia’s commitment to rigorous oversight and alignment with international sanctions regimes. From this foundation, Armenian authorities have introduced a set of pragmatic enforcement measures, such as transit declarations and electronic invoicing of air exports to EAEU destinations. Not only do these measures enhance the traceability of goods, but they also enable more efficient monitoring of exports, particularly those transiting or destined for Russia.
This tighter control has already generated a measurable impact. A representative from the State Revenue Committee said that in 2023 fines were imposed on illegal exports of dual-use items, and as a consequence such exports to Russia had fallen dramatically, with volumes reportedly at near-zero. This is a desirable outcome that is testimony to Armenia’s growing ability to restrict illicit trade in sensitive goods. Still, however, the official highlighted that there are issues at play, primarily in detecting more sophisticated evasion tactics. One such issue is Harmonised System code manipulation, the practice of mis-stating commodities to avoid the prohibitions of sanctions. Such breaches, both intentional and inadvertent, underscored the necessity of building stronger technical ability on the part of traders and supply chain providers to detect and neutralise such actions.
In strengthening financial regulation in Armenia, another milestone was the acknowledgement of cryptocurrency as a possible avenue for illicit financial flows. Participants discussed the need for strict regulation in this case. One of the CBA representatives explained that the government is formulating overall policies for how to tackle these matters. This also includes the draft law on crypto financial assets, which has already passed on the first reading in parliament. The aim of this provision is to encourage security and order in the digital currency market to facilitate openness of ownership, source of funds monitoring, and safeguarding of the financial system against abuse.
Building on Armenia’s increasing focus on the enforcement of sanctions, the role of the financial intelligence unit (FIU) has assumed a central position in addressing new risks and adhering to international frameworks. A key mechanism through which it achieves this is the analysis of suspicious transaction reports (STRs), which are filed whenever there are concerns regarding potential sanctions violations. According to a representative of the FIU, STRs are reviewed in the broader context of anti-money laundering systems and only reported if there is a clear suspicion of a link to criminal activity or illicit proceeds. The analysis of such reports has shown trends reflecting that individuals are involved in efforts to circumvent sanctions. Rather than engaging law enforcement directly at this stage, the FIU coordinates with the concerned department responsible for sanctions supervision to ensure preventive actions are undertaken where possible. While there is cooperation with foreign counterparts, for example, the Egmont Group, the representative acknowledged a gap in reciprocal investigation requests from foreign governments, which is a deficiency in Armenia’s overall sanctions enforcement system.
Private Sector Response and Unintended Consequences
Armenia’s efforts to comply with international sanctions have had a wide-ranging impact on the country’s private sector. Following the sanctions on major Russian banks, Armenian financial institutions and trade operators have had to quickly shift how they connect to the global financial and trade systems.
Prior to the Russian full-scale invasion of Ukraine and the subsequent implementation of G7 sanctions, Armenian banks mainly used Russian banks as their correspondent banking relationships with the international financial system. Since these major Russian banks (notably VTB and Sberbank) have now been sanctioned, Armenian banks have had to rewire their connections to the international financial system. Although a US bank continues to provide this service to one Armenian bank, no other Western banks have been willing to step in to fill the gap left by the Russians.
The impact of sanctions has led to the introduction of more stringent procedures within Armenia’s banking system. Participants noted that while the measures are generally seen to be effective in imposing compliance with international sanctions, they also complicated banking procedures. An NGO representative commented that over the past three years, Armenia’s banking system has undergone a substantial tightening of regulatory practice, with financial agreements becoming more restrictive. This shift can be seen in the increased recruitment of compliance officers across the sector. In the meantime, these heightened demands have added layers of complication for entrepreneurs and citizens conducting their routine banking transactions.
The impact of sanctions is not only felt in the banking sector but also by small businesses and producers. According to a Ministry of Economy representative, these firms are now under more scrutiny, with banks asking them to identify their end customers before transactions are approved – a demand that is challenging for many small firms to meet.
This intensified due diligence has translated into mounting operational pressures. Participants pointed to concrete obstacles such as delayed transactions, derisking by financial institutions and restricted access to correspondent banking services. These disruptions have had a disproportionate effect on smaller businesses, whose limited leverage and capacity make them more vulnerable to financial bottlenecks. One constant issue permeating participant discussions was the uneven enforcement environment: as larger businesses have generally been able to handle matters through unofficial networks or available ties, small actors remain in the position of lingering uncertainty and organisational disarray.
Participants highlighted that Armenian businesses, particularly small ones, cannot survive without their economic connections with Russia, as the access to the EAEU market and Russian online stores still offers vital opportunities that are not readily available in European and American markets. This concern was repeated by a Ministry of Economy official and one MP, who quoted testimony from local businesses, a good number of which view Western substitutes as insufficient. The MP added that Western partners have not made a strong counter- offer, as yet, and most in the private sector view those alternatives that have been offered as lacking what is necessary to enable a serious move away from Russia.
The implications of sanctions have also been felt acutely in the country’s IT sector. Participants noted that the industry has been disproportionately impacted by Western technology firms’ overcompliance policies, where they have cut back or entirely shut off their services or cooperation with Armenian counterparts based on perceived compliance risk. A representative of the Ministry of High-Tech Industry of the Republic of Armenia expressed concern over the UK’s warning to British exporters to avoid dealing with those that can assist in circumventing sanctions against Russia. Consequently, Armenia’s high-tech sector has suffered significantly, slowing its general development and making developments in the industry more challenging.
Although significant steps have been taken by Armenia to strengthen sanctions compliance infrastructure, participants emphasised that sufficient monitoring of cash flows continues to be a key vulnerability. This concern was raised repeatedly as a systemic flaw with limited transparency of financial flows causing potential loopholes that might be exploited to bypass sanctions, highlighting the necessity for enhanced oversight tools and ongoing institutional capacity building.
Another key point raised by participants was the role of public–private partnerships (PPPs) and cross-sector coordination in strengthening Armenia’s sanctions compliance efforts. It was underlined that there is already significant cooperation between the private and public sectors, which can form a solid foundation for progress. For example, the interagency committee, headed by the deputy prime minister, includes representatives from the private sector. It offers a platform for consultation on issues such as the risks sanctions pose to financial inclusion. A representative from the CBA noted that PPPs are extremely strong in areas such as anti-money laundering and counterterrorism financing (AML/CTF). By the end of 2024, several meetings had been held to discuss the findings of the National Risk Assessment (prepared in advance of Armenia’s ongoing Financial Action Task Force/MONEYVAL evaluation), namely money laundering and terrorism financing risks, reflecting the growing institutionalisation of these collaborations.
Along with national efforts, regional cooperation was also considered essential. Participants emphasised the importance of enhancing data sharing and joint development of typologies of risk to more effectively identify and deter sanctions evasion. In preparation for the ongoing MONEYVAL evaluation, stakeholders recommended intensifying public–private dialogue, further enhancing national risk assessments, and drawing on international experience to align Armenia’s compliance practice with evolving global standards.
Election Integrity and Financial Flows
Participants highlighted enduring vulnerabilities in the country’s electoral finance system, as Armenia moves towards its 2026 parliamentary elections. The main issue focused on gaps in enforcement. While the legal framework is in place, stakeholders widely described its implementation as irregular and insufficient.
Armenia’s Corruption Prevention Commission, tasked with supervising financial disclosures, faces serious limitations that risk undermining the integrity of elections. Among the primary issues, an NGO representative said, is the severe shortage of staff – typically, only one or two officials are assigned to scrutinise complex financial statements. This lack of resource seriously hampers the Commission’s ability to put its mandate into practice, causing delays in analysing asset declarations and impediments to their timely and transparent disclosure to the public.
These institutional limitations are exacerbated by the comparative shortness of the official campaign period – only three weeks. The participants agreed that the brevity of this time period makes effective observation impossible and rules out a careful examination of election-related financial activity.
In addition to structural and procedural flaws, participants also flagged issues about the application of campaign finance laws in Armenia. During previous election cycles, there were instances of apparent violations of campaign finance regulations that did not lead to significant consequences, raising concerns that similar issues might rise again. A representative of an NGO explained how a ban on corporate donations to election campaigns has been circumvented. In one case in 2018, two large factories were involved in questionable campaign finance operations, with investigations later showing that employees of the factories appeared to be contributors to political parties. This raised strong suspicions that their names were being used without their knowledge to conceal corporate interests and avoid the ban.
To counter such transparency issues, a CSO representative deliberated on Armenia’s beneficial ownership transparency reforms as a way of raising accountability. Under the current regulations, all legal persons, including NGOs and private entities, are required to annually disclose their beneficial owners. The potency of this move is, however, undermined through weak implementation. According to a representative of the Ministry of Justice, the authorities currently lack the capacity and resources to verify whether the declared owners actually own the entities, thereby creating the opportunity for misuse and further complicating efforts to prevent illegal company donations and guarantee transparency in the election process.
These past experiences, combined with experiences other countries have had with elections, have fuelled heightened concerns that foreign interference will escalate as the election approaches. Participants cited Russia’s efforts to interfere with the electoral process in Moldova, Georgia and Romania, and indicated that Armenia could be vulnerable to similar attempts. Among the principal issues raised was the potential for extraterritorial influence, such as online political advertisements financed from abroad. The NGO representative cited Russia’s use of 27,000 accounts in Moldova to interfere in the country’s elections and warned of the challenge of prosecuting such activity in Armenia’s elections outside its borders. In addition, CSO representatives pointed out techniques applied in Moldova, where individuals were reportedly encouraged to open bank accounts in Russian banks and were immediately credited with amounts ranging from €50 to €100. This represented a form of vote bribery, which made participants suspicious about the likelihood of Russia employing similar methods in Armenia, as the country has vulnerable groups facing financial difficulties who could be manipulated through such tactics.
To this array of concerns, the increased impact of media channels was added as a notably important line of foreign interference. Various new media channels, which participants assumed to be financed by Russian-affiliated interests, were spreading propaganda that corresponds with the Kremlin’s agenda. As one participant recognised, some media outlets adopt names suggesting pro-European interests while propagating anti-Western and anti-government themes. The participant gave the example of Euromedia24, a media source that, even with a pro-European name, has been working actively to disseminate anti-Western rhetoric.
Participants agreed that Russian influence is not merely at the media level, reaching as deep into think tanks and NGOs. Such entities are accused of actively working against Armenia’s democratic reforms, frustrating peace and normalisation efforts with Turkey and Azerbaijan and threatening to destabilise the foundations of democracy in the country. Participants warned that the scope and intensity of such activities are likely to grow as the 2026 elections draw closer.
Another risk highlighted for the 2026 election financing system is its transnational ties to Russia’s large diaspora community. Participants warned that such bonds between communities can be used for unlawful political financing or interfering in elections. Remittances and unregulated money transfers are prevalent in Armenia, posing enormous regulatory difficulties. In addition, the beneficiaries of Russian financing may unknowingly be caught up in influence operations due to the absence of stringent controls to check against such abuse.
Further adding complexity to these risks, diplomatic officials raised concerns that Nagorno-Karabakh forced displacement provides increased numbers of vulnerable populations to be targeted. These communities are exposed to greater risks of manipulation by vote-buying and informal financial assurances that damage electoral integrity.
Another key threat identified by participants is the presence of Iranian and Russian banks operating in Armenia, which produces alternative financial systems and deepens existing difficulties. The lack of transparency of such entities, combined with incomplete integration into the compliance system in Armenia, allows room for foreign actors to use them as backdoor conduits of finance to shape local political processes during election periods without being discovered.
These foreign influence concerns are further fuelled by the Armenian financial regulatory system that, according to participants, leaves loopholes for illegal financing to find its way into politics. In response to these complaints, an FIU official explained that while the FIU’s mandate does not directly cover political parties or elections, their activity becomes relevant as and when suspicious signs of a crime – in the form of illegal enrichment or money laundering – are detected. In such cases, the FIU cooperates with the banking sector and law enforcement agencies. Armenian AML/CTF legislation prescribes specific high-risk categories, including politically exposed persons, by which financial institutions are allowed to apply automated screening systems and flag suspicious activity for deeper scrutiny.
Another threat on the horizon raised by participants was the use of huge cash payments and cryptocurrency as instruments of illicit election funding, which go undetected with ease. To address these growing threats, an FIU official disclosed that the unit is now using blockchain analysis software in tracking cryptocurrency transactions and searching for warning signs. In an effort to close continuing gaps, the FIU is working to develop mechanisms for better early detection and surveillance. In terms of cash transactions, the official noted that any transaction exceeding $10,000 must be declared, with the data inputted into the FIU strategic analysis systems to help identify anomalies as well as block systemic threats to financial integrity and the electoral process. As the election looms, civil society representatives have registered alarm over the lack of effective mechanisms to track and monitor illicit financial flows amid increased risks of foreign interference. CSO members urged authorities to strengthen coordination and cross-sectoral collaboration and further underscored the need for more cross-country collaboration between Armenia and other countries that face risks of foreign election interference.
Apart from the national efforts, participant discussions then turned to the role of international institutions such as MONEYVAL, considered to be one of the most important stakeholders in improving the electoral security of Armenia. MONEYVAL has so far been anti-corruption oriented, but participants emphasised the necessity for their agenda to be broadened to encompass electoral integrity. With an in-country evaluation to be conducted in October 2025 and the final report published in 2026, Armenia has a great chance to learn some meaningful lessons and gain valuable recommendations, presenting the country with a genuine chance to strengthen its mechanisms against electoral vulnerabilities.
Summary
Armenia finds itself at a financial and trade crossroads, caught between the West and the targets of sanctions (Russia and Iran) and facing financial headwinds that may threaten the integrity of its 2026 election. While the country has strong legislation in place, a financial sector that is alert to the threat posed by sanctions evasion, a vibrant civil society and an experienced anti-financial crime community, it will need to embrace a whole-of-society approach to bring together these capabilities to ensure the integrity of its financial system in the face of persistent and rising challenges.
Irina Mamulashvili is a Russia Sanctions Implementation Project Officer at the Centre for Finance and Security at RUSI. She organises workshops on Russian sanctions throughout the EU and internationally. Additionally, she coordinates a counterterrorism financing project.
Kinga Redlowska is the Head of RUSI’s Centre for Finance and Security (CFS) Europe. She leads the activities of CFS in Brussels that centre around the intersection of illicit finance and security, and are focused on the EU and its neighbourhood.