Teaching the Business and Art of Sanctions Circumvention

For many years, a Google search for sanctions courses would have turned up an array of opportunities for bankers and lawyers to hone their understanding of sanctions compliance as part of their job. Academic interest was limited and specialised – and courses appealing to those with such an appetite were few and far between.

Yet today, if you visit the website of a European university like King’s College London, you’ll find plenty of academic courses focused on different elements of international security. Topics related to finance and security are not exempt. Courses with titles such as ‘Sanctions and Statecraft’ or ‘Sanctions and Economic Warfare’ catering to students and the generally curious alike have sprouted across the academic landscape.

These courses advertise themselves as offering the opportunity to explore ‘how sanctions operate as tools of coercive diplomacy in global politics – from their historical evolution to the strategies states use to design, deploy, and resist them’ or exploring ‘the international political economy of sanctions in the constantly changing context of economic warfare and geopolitical rivalry’.

This is not surprising. Given the rate at which banks, law firms and ministries of foreign affairs and finance are hiring staff with an understanding of sanctions, universities are tapping into a demand signal that is too strong to ignore.

This expertise is sorely needed, particularly if it comes with the perspective provided by academic study. One of the author’s favourite questions to policymakers – when he gets the chance – is to ask for a show of hands from those that worked in the sanctions field before February 2022. The display is always sparse, and the hands that are raised normally belong to those from the US government.

Those sitting in London, Brussels or EU member state capitals have been consumed with sanctions thinking for over three years. When is the next EU package? What are we doing about the shadow fleet or the role of cryptocurrencies in sanctions evasion? Why is there not more enforcement of sanctions evasion? Are sanctions actually working? Politicians herald the latest sanctions as the ‘strongest ever’ (until the next package comes along), ‘world’s first’, ‘the largest to-date’ and other superlatives.

But that’s in the West. What of the view from Russia, which was the focus of the majority of these sanctions over the past three and a half years?

The View from Over There

In Moscow, political voices dismiss the threat of sanctions as a ‘theatrical ultimatum’ and point to the country’s development of ‘immunity’ to sanctions. On the surface, they might have a point. The war continues and Russia’s military shows no sign of running short of the funding and resourcing that the sanctions seek to restrict, despite the clear and constant deterioration of the Russian economy. This is in part because the sanctions are not applied universally, and countries like India and China continue to supply Russia with oil and the military supplies it needs, despite the illegal nature of the Kremlin’s war in Ukraine. But it is also because Russia and its leadership treat avoiding and evading sanctions as an existential challenge.

In response to Russia’s sanctions evasion, in the past three years, G7 governments have published a mushrooming array of advice and alerts in an attempt to confront these acts of circumvention. But they have not matched Russia’s urgency to build its defences against the impact of sanctions with a similar commitment to implementing and enforcing their own guidance and alerts.

Yet, with Vladimir Putin showing no sign of relenting in his war of choice in Ukraine, sanctions circumvention is going to remain a central pillar of Russia’s economy in the years ahead. And this involves employing all the illicit finance and procurement tools in the box including the use of front and cut-out companies and cryptocurrencies, tools that need a growing degree of illicit finance expertise.

Teaching Circumvention

It is therefore not surprising that just as the rise in demand for sanctions expertise has fuelled developments in higher education in the West, so too is demand for sanctions circumvention skills, offering a boost to universities in Russia.

Providing advice on sanctions circumvention is not new. In a high profile case, Virgil Griffith (a US citizen) was arrested in 2019 – and subsequently prosecuted and imprisoned – for providing advice to North Koreans on how to evade sanctions and launder money using cryptocurrencies at a conference convened in Pyongyang.

Yet such previously ad hoc advice is now, seemingly, being industrialised by Russian universities to meet the existential need to professionalise the nation’s ability to circumvent sanctions. The recently illuminated case of Moscow’s Higher School of Economics (HSE) is the most high profile programme brought to light to date, where a course on sanctions compliance is mandatory for students in the international law department.

But this is just the tip of the iceberg. HSE offers four dedicated courses on compliance and sanctions including a master’s programme in international corporate compliance and business ethics. This is marketed as a ‘first-of-its-kind’, a two-year, full-time master’s programme costing 490,000 RUB/year (£4,643). Launched in 2020, it trains students to ‘learn how to detect risks of sanctions and/or other adverse effects on companies caused by supervisory authorities, conduct compliance studies, pinpoint legal means to minimise companies’ risks, and develop internal regulations in the field of corporate compliance control etc’.

HSE also offers a sanctions compliance course for professionals. This is an online programme launched in 2022, costing 84,000 RUB (£795). The course invites participants from legal, government relations offices, representatives of ministers and, interestingly, managers and employees of subsidiaries of foreign companies in Russia. As a result of the course, participants will be able to ‘identify areas of risk of secondary sanctions and coercive measures of foreign and Russian regulators in the process of transactions with Russian and foreign persons’. Another course offers master classes on: ‘The EU and sanctions: where are the weaknesses in 2025?’; ‘Formation of Sustainable International Business Partnerships in the Context of Sanctions Restrictions: Risks and Opportunities’; and the tempting ‘Sanctions labyrinth: how not to be hit by primary and secondary restrictions’.

More specific courses are also available. For example, Moscow Witte University offers a professional development programme on cross-border payments in the era of sanctions, which helps participants ‘consider new approaches to the organisation of cross-border payments, including the use of cryptocurrencies and digital currencies, as well as the opportunities offered by the BRICS countries’.

The Kremlin’s full-scale invasion and nightly bombardment of Ukrainian cities continues with, tragically, no end in sight. The call in Europe and from Kyiv for increased sanctions continues too, as do the business opportunities for law firms, universities and others to provide the advice and training needed on both sides of this war. The core question is who is more seriously committed to their sanctions-related mission?

The Kremlin views itself as being at economic war with the West, thus requiring a whole-of-society response including training future generations in the art of sanctions circumvention and new approaches to cross-border payments that avoid the US dollar and other western currencies. The counterparts of the troops being thrown into the meatgrinder in Eastern Ukraine are the businessmen, accountants and financiers learning these new tools.

Until the G7 and its sanctions implementation and enforcement efforts match the commitment with which their efforts are being met by Russia, political leaders in London and Brussels need to reflect on whether their sanctions superlatives are really appropriate. Certainly those under constant air and artillery attack in Ukraine would conclude: ‘could do better’.

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