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
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 corpora