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Investigations
We are available to act as independent or joint experts in export control, sanctions, and military supply chain investigations.
Our investigators have led United Nations Security Council sanctions investigations; provided partner-level compliance and investigation advisory to international banks in Russia, Ukraine and the European Union; worked with law enforcement agencies on sanctions and export control investigations; and tracked illicit military and dual-use goods acquisition by sanctioned states and terrorist groups on the ground in Eastern Europe, the Middle East, Africa and Southeast Asia.
Collaboration
We work collaboratively in large, multifunctional teams of investigators, experts and NGOs.
We are happy to work together with other groups investigation sanctions evasion, including for the purpose of war crimes litigation. We are also able to provide financial investigations support to complement other types of cases, including war crimes, crimes against humanity, export controls violations, and litigation.
We are also happy to partner with other organisations to help disseminate research and investigations findings in ways that support action in the private sector. We are happy to partner with you to draft typologies, including in content for our newsletter.
Advisory & training
We are also available to act as experts to support the design and function of your company's due diligence process.
In addition to investigations expertise, our experts have supported many companies to improve their due diligence and sanctions analysis procedures. We can provide training for staff, regarding sources of information for due diligence.
We can also provide training on recent evasion and circumvention trends in sanctions evasion and circumvention.
Collectively, SECTA’s experts have decades of experience of working with banks, regulators, law enforcement, sanctions bodies, and export control authorities. We continue to maintain their knowledge as practitioners: providing expert witness services in cross-border fraud and corruption cases; and tailored support to bank compliance functions in Europe and Southeast Asia.
Our expertise
Financial network analysis
We use asset-tracing and intelligence-led investigations methods to map complex, global networks supporting sanctions evasion and circumvention. We use a variety of corporate, business, and financial data to identify transfers of restricted goods and the funds flows that accompany it.
Tracking military and dual-use goods
We focus on countering proliferation and high-value military-industrial goods. Our experts have led United Nations Security Council sanctions investigations; worked with law enforcement agencies on sanctions and export control investigations; and tracked illicit military and dual-use goods acquisition by sanctioned states and terrorist groups on the ground in Eastern Europe, the Middle East, Africa and Southeast Asia.
High-impact reporting
We target our reporting so that our different audiences can make decisions.
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Q&A
They open and close shell companies around the world. They change routes, logistics and financing methods to ship military, dual-use and economic commodities while evading detection. Our investigations must be agile and action-oriented to disrupt them. But they rely on trusted networks, often involving people and businesses with a track record of sanctions circumvention, or close links to security and intelligence services, which we can identify. Identifying networks and network types will have a greater impact than targeting any single person or shell company, solving the “whack-a-mole” problem.
UN and other multilateral trade sanctions regimes already place obligations on financial services providers, though they are often overlooked. US, UK and EU authorities threaten repercussions on banks for processing payments or financing for Russian export control evasion. However, banks and other regulated entities often lack compliance mechanisms to detect trade sanctions violations. Their data does not contain sufficient detail to screen transactions against sanctioned goods lists. They are accustomed to screening for sanctioned people and companies: their most effective detection mechanisms use intelligence-driven client and counterparty analysis. They need to convert illicit commodities into red flags about entities. This is what SECTA’s typologies do.
Sanctioned goods are increasingly procured in, and shipped through, jurisdictions where regulations are not enforced. But the need to pay legitimate suppliers means that payment and financing for them must often still pass through the formal financial system, via financial institutions in jurisdictions with the legal frameworks and political will for enforcement. Given the right information and analysis, banks and other financial services providers could drive the detection and disruption of trade sanctions evasion networks.
Sanctioned goods are increasingly procured in, and shipped through, jurisdictions where regulations are not enforced. But the need to pay legitimate suppliers means that payment and financing for them must often still pass through the formal financial system, via financial institutions in jurisdictions with the legal frameworks and political will for enforcement. Given the right information and analysis, banks and other financial services providers could drive the detection and disruption of trade sanctions evasion networks.