The Capacity Building Training on “Conducting Appropriate and Effective Oversight of Sanctions Requirement Implementation by Business Operators for national competent authorities responsible for the oversight of sanction restriction implementation required under EU Regulations applied following Russia’s illegal invasion of Ukraine (NCAs)” was organised in Larnaca, Cyprus, by the Council of Europe’s Economic Crime and Cooperation Division, under the joint EU – SG REFORM and Council of Europe Technical Support Instrument (TSI) project on “Effective implementation of the sanctions regime and enhanced cross-border cooperation in EU Member States”. The workshop was followed by a half-day hybrid training session for business operators and National Competent Authorities (NCAs) on "Preventing Misuse of Designated Non-Financial Services Businesses and Professionals (DNFBPs) to Facilitate Sanctions Evasion".
This bespoke workshop, designed specifically for sanction NCA staff, brought together representatives of the NCAs from 16 Member States, including Belgium, Croatia, Cyprus, Czechia, Finland, Germany, Hungary, Latvia, Lithuania, Luxembourg, Malta, Romania, Slovakia, Slovenia, Spain and Sweden. The event provided NCAs with the opportunity to share best practices and exchange views on challenges faced in ensuring the effective oversight and enforcement of sanction restrictions.
The workshop promoted a holistic supervisory approach, reviewing the importance in understanding and assessing sanction risks and vulnerabilities, to develop appropriate and effective risk-based supervisory planning. Tactical activities and supervisory measures including the conducting of onsite examinations, collection of data, assuring the accuracy and completeness of asset freezing reports, and measures to verify business operator compliance with both sanction restrictions and derogations granted, were addressed. The importance of conducting effective due diligence on entity owners and controllers and achieving a balance between emphasising list screening with activity-based monitoring was an important element explored, using practical examples and exercises. NCAs also explored the use of enforcement measures for non-compliance by business operators, and its role in both deterring and preventing such behaviour. Participants engaged in interactive working exercises and in a tour-de-table type discussions which canvassed best practices, lessons learnt to and planning effective responses to emerging and evolving sanction compliance risks.
A separate training, forming a part of a wider series of dedicated training sessions organised for both business operators and NCAs under the Project, was held on 26 September 2025 focused on the topic of misuse of DNFBPs in the EU to facilitate sanctions evasion. The final session of this series, which has seen over 1500 participants since it was launched in April 2025, hosted over 190 participants from a wide range of financial services and DNFBP representatives, who learnt about recent typologies and red flags indicating DNFBP services’ misuse, measures that can be used to mitigate and prevent such misuse and emerging risks linked to DNFBPs as service providers and clients of other business operators. The training included several case studies on how illicit actors misuse DNFBPs to evade sanction restrictions, which were commented upon by participants who took part both in person and online.
The event was organised within the framework of the Technical Support Instrument initiative “Effective implementation of the sanctions regime and enhanced cross-border cooperation in EU Member States”, co-funded by the European Commission’s Secretariat-General, Structural Reform and Investment Task Force and the Council of Europe and implemented by the Council of Europe.
