European Sanctions and Illicit Finance Monitoring and Analysis Network (Euro SIFMANet)

Euro SIFMANet brings together European research institutions to raise awareness and inform policymaking against the illicit financial flows that continue to undermine our democracies.




Anatolyi Deryenko / Alamy Stock Vector


SIFMANet is a collaborative network, led by the Centre for Financial Crime and Security Studies at RUSI, in collaboration with RUSI Europe, and supported by the National Endowment for Democracy. The network aims to bolster the response of EU member states to the national security threat posed by illicit finance to democracies and to provide viable policy recommendations.

The Russian war in Ukraine has shattered the stability of Europe and brought to the fore the role of finance in international security. Yet very rarely is the national security threats posed by illicit finance to our societies considered, allowing it to subvert European democracy and threaten the rule of law.

SIFMANet will bring together European civil society and academic experts to engage with governments and their private sectors in boosting the ability of the EU to think about and respond to illicit finance beyond the criminal dimension.

Anatolyi Deryenko / Alamy Stock Vector

Updated recommendations


SIFMANet - 2024 Recommendations: Making Sanctions Work

As SIFMANet continues in its second year it is updating its recommendations to make Russia sanctions work in 2024.

SIFMANet: A Year in Review Strengthening Sanctions Against Russia


The SIFMANet Sanctions Brief


Objectives

As a vibrant network of various European research institutions, SIFMANet intends to address identified shortcomings and unanswered challenges that EU member states face. It aims to:

  • Promote the effective implementation of EU sanctions on Russia by bolstering the under-resourced and over-stretched capacity of member states.
  • Highlight the importance of applying a national security lens to the threats posed by illicit finance to the EU and connected states and their democratic systems.
  • Create a network of EU academic and research institutions that work together to ensure sanctions and illicit finance remain central to the EU security and policy agenda, as part of the wider EU focus on defending democracy.

Sanctions Effectiveness: The Role of Data

David O'Sullivan: Behind the Scenes of EU Sanctions Diplomacy

Making Sanctions Work: Euro SIFMANet

CFCS Director Tom Keatinge Address to the Annual AML Center Conference 2023

Roundtables

Read the roundtable discussion summaries and watch some of the session recordings

Euro SIFMANet: Tbilisi Report

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Euro SIFMANet: Barcelona Report - The Role of Data in Sanctions Implementation

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Euro SIFMANet: Stockholm Report

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Euro SIFMANet: Madrid Report

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Euro SIFMANet: Riga Report

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Euro SIFMANet: Warsaw Report

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Euro SIFMANet: Paris Report

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Euro SIFMANet: Prague Report

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Euro SIFMANet: Berlin Report

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Euro SIFMANet: Vilnius Report

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Summit

The SIFMANet Summit on 9 March 2023 convened the network’s experts from across Europe to address the challenges of effective implementation of sanctions against Russia, by exchanging best practices and examining viable solutions on national and European levels.

Opening remarks


How to maximize the impact of sanctions against Russia


Euro SIFMANet: SIFMANet Summit Summary
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Recommendations for Effective Sanctions Against Russia

SIFMANet has collected recommendations to be actioned in order to overcome the implementation challenges identified and enhance the effectiveness of its restrictive measures against Russia.

SIFMANet - 2024 Recommendations: Making Sanctions Work

As SIFMANet continues in its second year it is updating its recommendations to make Russia sanctions work in 2024.

Network members and sponsor

  • Center of Excellence in Anti-Money Laundering, Lithuania

    The Centre of Excellence in Anti-Money Laundering (AML Centre of Excellence) combines the efforts of public and private sectors in strengthening the framework on anti-money laundering and counter terrorist financing (AML/CTF).

    Find out more
  • Clingendael Institute

    The Clingendael Institute is an independent think tank and academy on international affairs, based in The Hague. Through its analyses, training, publications and events, Clingendael aims to inspire and equip governments, businesses, and civil society in order to contribute to a secure, sustainable and just world. Clingendael offers 40 years of top knowledge and training.

    Find out more
  • Equilibrium Institute

    The Equilibrium Institute is Hungary’s independent think tank. In order to renew the political discourse in Hungary, we draft political, economic and cultural future visions and write detailed policy proposals and strategies based on these visions. We are engaged in an ongoing dialogue with the most important political, economic and cultural decision-makers. We persuade them of the importance of implementing our policy proposals, and we provide expert assistance in the process of policy implementation.

    Find out more
  • Jacques Delors Centre, Hertie School, Germany

    At the Jacques Delors Centre, academic research goes hand in hand with the development of concrete ideas for future-oriented EU policies. In our think tank work, our analyses provide an independent, non-partisan view of European policy processes and decisions.

    Find out more
  • Hybrid CoE

    Hybrid CoE is an international, autonomous network-based organization promoting a whole-of-government and whole-of-society approach to countering hybrid threats. Participation in the Centre’s activities is open to all EU and NATO countries, and the number of Participating States has grown to include 32 states today.

    Find out more
  • IRIS, France

    The French Institute for International and Strategic Affairs (IRIS) is one of the main independent European Think Tanks on geopolitical and strategic issues.

    Find out more
  • International Centre for Defence and Security - Estonia (ICDS)

    ICDS aims to advance the transatlantic community’s strategic thinking on the security challenges facing the Baltic-Nordic region, from armed or cyber attacks to threats against social cohesion and energy security.

    Find out more
  • Latvian Institute of International Affairs (LIIA)

    LIIA is Latvia’s oldest research center, and it is the country’s best known and most internationally recognized think tank specializing in international affairs. The Latvian Institute of International Affairs was established in Riga on 20 May 1992 and was initially funded by a number of grants from the Swedish government to support research on the security of the Baltic States. The transfer of skills and knowledge has been greatly facilitated by its long-standing cooperation with the Swedish Institute of International Affairs.

    Find out more
  • The Polish Institute for International Affairs (PISM)

    The Polish Institute of International Affairs (PISM) is a leading Central European think tank that positions itself between the world of politics and independent analysis.

    Find out more
  • Prague Security Studies Institute

    The Prague Security Studies Institute (PSSI) is dedicated to identifying and analysing a range of security-related challenges facing the post-communist states and allied partners worldwide, with a focus on countering economic and financial hybrid warfare and threats to the space domain.

    Find out more
  • Regional Institute for Security Studies (RISS)

    The Regional Institute for Security Studies (RISS) is an independent, non-partisan research Institute with a focus on defence, security and intelligence studies. RISS provides independent research and analysis on a wide range of regional and global challenges with a special focus on the wider Black Sea region and its importance for international actors. RISS operates in partnership with the Royal United Services Institute (RUSI).

    Find out more
  • RUSI Europe

    Based in Brussels, RUSI Europe builds on the Royal United Services Institute’s almost 200 years of expertise in security and defence. We carry out research, provide a forum for security and defence dialogues, and are committed to help solve the most urgent security and defence challenges. Our mission is to leverage the Institute’s research capacities to inform policy-making at the EU, NATO and among their member states.

    Find out more
  • Stockholm Centre for Eastern European Studies (SCEEUS)

    The Stockholm Centre for Eastern European Studies (SCEEUS) is an independent centre of knowledge based at the Swedish Institute of International Affairs (UI). The geographical scope of SCEEUS comprises Armenia, Azerbaijan, Belarus, Georgia, Moldova, Russia and Ukraine.

    Find out more
  • Think Tank EUROPA

    Think Tank EUROPA is an independent Copenhagen-based think tank focusing on Europe. We strive to ensure that European affairs with a Danish perspective become more visible in national policy debates.

    Find out more

Project sponsor

  • National Endowment for Democracy (NED)

    The National Endowment for Democracy (NED) is a private, non-profit foundation dedicated to the growth and strengthening of democratic institutions around the world. Each year, NED makes more than 2,000 grants to support the projects of non-governmental groups abroad who are working for democratic goals in more than 100 countries.

    Find out more

Latest publications

View all publications

    In the News archive


    In the Newsquote
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    These methods [of sanctions evasion] are becoming incredibly complex. Before we checked two levels of ownership to find sanctions evasion, now you have thirty levels of ownership, and you have to plough through countless shell companies.

    Gonzalo Saiz

    CFCS Research Analyst

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    In the Newsquote
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    Not all EU states implement sanctions as rigorously as they could, either by not having criminalised evasion, or by having complex government structures, or by not having enough personnel, etc...

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    Countries like Georgia have found themselves in a very tough position because they they're being almost made to choose - do you want to be with the EU, do you want to be with Russia? How do you stay in the middle?

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    There will always be holes in the net of sanctions surrounding the Russian economy, but we must try and make that net as small as possible, and we must continue to respond to those holes.

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    the EU will tighten its sanctions policy from next year. Those people who are confirmed to have contacts with Russian oligarchs will be blacklisted...

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    We will see the EU become tougher and the messages from Brussels stronger, but the EU does not want to implement heavy sanctions against third countries.

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    The countries that have historically close economic ties with Russia are vulnerable to acting as gateways for exports to Russia."

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    [The Russian aggression against Ukraine] was an opportunity to do something that we should have done a long time ago: to question ourselves regarding the influence that [oligarchs] bought with their money within our society.

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    Putin organised this meeting with the oligarchs, then photographs were published. So he infected them, he prevented them from dissociating from him.

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    Keep in mind that sanctions are decided in Brussels, but each Member State decides how to implement them. Spain, for example, can decide whether to ban a company controlled by a Russian oligarch. I believe that the fact that each one decides for himself, that is, the lack of harmonisation, can cause gaps that the sanctioned company or person can take advantage of.

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    So far, our focus has been more on creating the sanctions, not on implementing them."

    Gonzalo Saiz

    CFCS Research Analyst

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    In the Newsquote
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    The statistics are suspicious. Why did these countries suddenly need an unprecedented amount of European Union (EU) goods? It is likely that a lot of our exported production goes to Russia.”

    Gonzalo Saiz

    CFCS Research Analyst

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    In the Newsquote
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    Sanctions are long-term working tools, not like switches that turn off the economy like a light bulb, so their impact on Russia is only beginning to manifest, Tom Keatinge, director of the Financial Crimes and Security Research Centre of the British security and defence think tank RUSI (The Royal United Services Institute), told ERR in a statement.

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    RIGA - Latvia's stance in relation to sanctions against Russia is very serious and determined, said Tom Keatinge, Director of the Centre for Financial Crime & Security Studies (CFCS) at The Royal United Services Institute (RUSI), in an interview with LETA. "Of the countries we have visited, you are the most determined ones. Not only in words, but also deeds. There were no questions you people could not answer," he said.

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    Beyond adding ever more products, entities and people on the list of sanctions, Europe should also work on implementation and enforcement. To make sanctions work in practice, Europe must urgently start to dismantle financial secrecy that currently allows corrupt officials and businesspeople to circumvent sanctions and hide ill-gotten gains."

    Sebastian Mack

    Policy Fellow for European Financial Markets, Jacques Delors Centre

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    In the Newsquote
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    ...Latvia is among those countries that "both bark and bite" - so they are able to implement sanctions in real life as well. It's not like that everywhere. After the annexation of Crimea, the sanctions were weak, and we did not track how they were circumvented, as evidenced by the Russian invasion of Ukraine in February 2022, says Tom.

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    Tom Keatinge, Director of CFCS (Centre for Financial Crime and Security Studies), a research centre based in London, points to Turkey and the United Arab Emirates as being at the heart of these circuits. We can add Armenia, Kazakhstan or Georgia. According to the former banker, the system works in particular thanks to the more or less voluntary ignorance of Western companies: “They are in charge of applying the sanctions, but sometimes do not want to sacrifice their interests", deplores Tom Keatinge. When they suddenly see an increase in orders from a customer located in a suspicious country, they should ask themselves why. And who really is the purchasing entity. If they can't answer these questions, they shouldn't sell. He wants Western intelligence services "to ensure, by mapping the value chains, that there are no re-exports", modelled on the work of Israeli intelligence services to prevent Iran's nuclear proliferation...

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    Latvia went through a painful overhaul of the country’s financial system following the MONEYVAL assessment of 2018, but it worked out well as it meant that Latvia was better prepared when new sanctions on Russia were introduced."

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    For the first time, Europeans are putting in place sanctions targeting a country with which they are intimately linked, on commercial, financial or energy levels," says Tom Keatinge, of the British think tank Royal United Services Institute. Responsible for evaluating, country by country, the application of sanctions, he explains that “some fear that in wanting to strike the other, they strike themselves”.

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    Thanks to allies like Abu Dhabi, the Kremlin will not fall for a long time, says Tom Keatinge, head of the Centre for Financial Crime and Security Studies at RUSI.

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    Carolina Lewicka from Political Intelligence talks to Dr Kinga Redłowska from the Centre for Financial Crime and Security Studies of the Royal United Services Institute about how to design good and effective sanctions.

    Kinga Redlowska

    Head of CFCS Europe

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    In the Newsquote
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    I'm afraid that most of the oligarchs will get their property back. But Russia caused hundreds of billions of dollars worth of damage to Ukraine, and it should pay for it," says the head of the Center for Financial Crime and Security Studies at the prestigious British think tank RUSI.

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    Political leaders have not yet clearly defined what the goal of these sanctions is, perhaps they don't even know exactly. They introduced the sanctions under pressure, because not imposing them would disappoint both the voters and the Ukrainian state and send a clear signal to the Kremlin about the weakness of the West. In 2014, after the annexation of Crimea, the West imposed too soft sanctions, so now we have the last chance to show our tough stance against aggressive Russia..."

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    ...The sanctions bucket is still pretty leaky," says Keatinge. According to him, London will no longer be as welcoming a place for Russian oligarchs and their money as before, although British politicians also need to clean up their act and tighten the control of dirty or suspicious money. Keatinge leads a program mapping and combating dirty money at the UK's leading security and defense think tank RUSI. He was in Prague last week at seminars with Czech experts.

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    First of all, it should be said that it’s not an original idea because it was a point that was emphasised by the European Commission President Ursula von der Leyen in her State of the Union address in September. In any case, I think that for many years in Europe, when we thought about ‘dirty money’ we thought about criminal money coming from non-state actors, organised crime groups and and terrorists. But, of course, in recent months we’ve had very clear indications that money coming into the European Union is not only coming in for the purpose of crime but also to try and undermine our democracy, to sway elections, to buy influence....

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    Combating the financing of terrorist activity should be at the core of the security response, yet the policy community has seemingly moved on....

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    ...If we believe - in theory - that sanctions packages weaken over time because the strongest sanctions are adopted at the beginning, then I would expect policymakers and legislators to spend a lot of time making sure that the first, second, third packages are properly implemented. Because plugging small holes in one place will be in vain if water pours through a giant hole in another. I think the EU has worked well so far. Now there are two things to do. Countries need to do what Lithuania and some other countries are doing - to dig deeper into the packages and ensure that they are implemented wherever possible. The second thing is that more must be done to harmonize sanctions...

    Tom Keatinge

    Director, CFCS

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    In the Newsquote
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    Dirty money is undermining European democracy, and the effective implementation of sanctions against Russia is just part of an urgently needed response.

    Tom Keatinge

    Director, CFCS

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    RUSI launches a European Network to Monitor Sanctions and Illicit Finance

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