The UK’s National Crime Agency (NCA) has told banks to be on the lookout for attempts to evade export controls designed to starve the Russian military of key goods and technology.  

The alert from the NCA, which polices serious and organised crime, echoes a steady stream of notices from US authorities to banks, warning that they may be unwittingly used to processes sanctions-busting transactions.  

“Russia is exerting significant effort to procure sanctioned goods from other countries, including goods originating in the UK,” the NCA says in a notice published on December 6. “Russia is deploying complex supply chains and alternative supply routes to acquire sanctioned products.” 

The notice adds: “The financial sector plays a critical role in the procurement cycle. The UK government encourages the financial sector, including banks, credit card operators, foreign exchange dealers and non-bank payment service providers, to ensure they are maintaining vigilance against global attempts to circumvent trade sanctions.” 

Since the US, UK, EU and allied countries slapped comprehensive sanctions on Russia following its February 2022 invasion of Ukraine, new trade routes through third countries bordering Russia have sprung up to try to skirt export controls.  

Earlier this year the US Financial Crimes Enforcement Network said banks had reported some US$1bn of transactions that may have been linked to export control violations. 

Items most coveted by the Russian military include technology used in communications equipment and weapons systems.  

The UK, US, EU and Japan maintain a Common High Priority list of items subject to export controls and which the the British government says can be found on the battlefield in Ukraine. “Items on this list are at high risk of being used in Russian sanctions circumvention efforts,” the NCA says. “UK businesses should conduct due diligence to ensure that the end destination of these products is not Russia.”

The list also includes common dual-use items such as cameras, ball bearings and aircraft parts.  

The top item in a list of red flags issued by the agency on Wednesday is “transactions related to payments for goods on the Common High Priority list, from a company incorporated after 24 February 2022 and based in known diversionary destinations”. 

Countries identified by governments and research as key transshipment points for Russian-bound goods include Armenia, China, Georgia, Kazakhstan, Turkey, the UAE and Uzbekistan.  

Some of the red flags included in the notice are identical to those published in November by US government agencies, including “purchases under a letter of credit that are consigned to the issuing bank, not to the actual end user” and “supporting documents, such as a commercial invoice, [that] do not list the actual end-user”. 

The NCA also warns against transactions involving companies with little or no web presence, companies using phone numbers that do not match the destination country and customers which refuse to provide details about the end use of a product.  

In addition to financial institutions, the NCA says the notice should be read by non-regulated businesses such as customs brokers, freight forwarders and other transport providers.  

Also on Wednesday the UK government announced sanctions on a slew of businesses in Belarus, China, Serbia, Turkey and Uzbekistan, which it accused of helping supply the Russian armed forces. 

The government also sanctioned four United Arab Emirates companies it says are “using opaque corporate structures and deceptive shipping practices to facilitate unfettered trade in Russian oil”.  

The G7 and Australia last year launched a price cap on Russian oil exports, enforced through a ban on providing services such as financing and insurance to Russian oil shipments. 

Enforcement of the price cap has stepped in recent months, with the US in October sanctioning companies in Turkey and the UAE over alleged breaches.  

Swiss researchers said last month that around 80% of Russian-origin crude oil is being traded through Dubai and Hong Kong, following Switzerland’s enforcement of sanctions on the product.