Ships, Shells, and Sanctions: The EU’s Fight Against Trade-Based Sanctions Evasion - A legal analysis of trade misrepresentation techniques and the role of private sector actors in the enforcement of EU restrictive measures
(2025) HARN63 20251Department of Business Law
- Abstract
- This research investigates the legal framework of the European Union (EU) in addressing trade-based sanctions evasion, with a specific focus on the role of private sector actors, specifically financial institutions and shipping companies. Trade misrepresentation — a rising method for moving illicit funds through techniques such as under-invoicing, over-invoicing, phantom shipments, complex corporate structures and more — is a challenge to enforcing EU restrictive measures. With the enforcement delegated to Member States and further private actors, sanctioned entities attempt to mask their activities with legitimate commercial flows, exploiting legal loopholes.
Findings reveal a significant asymmetry in obligations for private entities:... (More) - This research investigates the legal framework of the European Union (EU) in addressing trade-based sanctions evasion, with a specific focus on the role of private sector actors, specifically financial institutions and shipping companies. Trade misrepresentation — a rising method for moving illicit funds through techniques such as under-invoicing, over-invoicing, phantom shipments, complex corporate structures and more — is a challenge to enforcing EU restrictive measures. With the enforcement delegated to Member States and further private actors, sanctioned entities attempt to mask their activities with legitimate commercial flows, exploiting legal loopholes.
Findings reveal a significant asymmetry in obligations for private entities: financial institutions face well-defined obligations, while the logistics sector operates under vague and fragmented guidance. Limited data access, transparency and self-reporting issues further undermine the detection of effective sanctions evasion. Despite regulatory progress, the current framework remains underdeveloped to effectively detect sanctions evasion via trade misrepresentation techniques. (Less)
Please use this url to cite or link to this publication:
http://lup.lub.lu.se/student-papers/record/9199861
- author
- Puchkova, Angelina LU and Jablonska, Oliwia Krystyna LU
- supervisor
- organization
- course
- HARN63 20251
- year
- 2025
- type
- H1 - Master's Degree (One Year)
- subject
- keywords
- EU sanctions, trade-based sanctions evasion, private sector compliance, trade misrepresentation, financial institutions, shipping companies, anti-money laundering, beneficial ownership
- language
- English
- id
- 9199861
- date added to LUP
- 2025-06-16 11:00:28
- date last changed
- 2025-06-16 11:00:28
@misc{9199861, abstract = {{This research investigates the legal framework of the European Union (EU) in addressing trade-based sanctions evasion, with a specific focus on the role of private sector actors, specifically financial institutions and shipping companies. Trade misrepresentation — a rising method for moving illicit funds through techniques such as under-invoicing, over-invoicing, phantom shipments, complex corporate structures and more — is a challenge to enforcing EU restrictive measures. With the enforcement delegated to Member States and further private actors, sanctioned entities attempt to mask their activities with legitimate commercial flows, exploiting legal loopholes. Findings reveal a significant asymmetry in obligations for private entities: financial institutions face well-defined obligations, while the logistics sector operates under vague and fragmented guidance. Limited data access, transparency and self-reporting issues further undermine the detection of effective sanctions evasion. Despite regulatory progress, the current framework remains underdeveloped to effectively detect sanctions evasion via trade misrepresentation techniques.}}, author = {{Puchkova, Angelina and Jablonska, Oliwia Krystyna}}, language = {{eng}}, note = {{Student Paper}}, title = {{Ships, Shells, and Sanctions: The EU’s Fight Against Trade-Based Sanctions Evasion - A legal analysis of trade misrepresentation techniques and the role of private sector actors in the enforcement of EU restrictive measures}}, year = {{2025}}, }