This ARGA analytical report examines the systematic abuse of sanctions mechanisms and anti-money laundering (AML) regimes in post-Soviet states. Drawing on open-source data, documented cases, and comparative legal analysis, the study explores how tools originally designed to protect the financial system are being used for political pressure, corporate disputes, unjustified asset freezes, and cross-border leverage through FIU channels and Interpol mechanisms.
The report presents a regional overview, country-specific analyses (Kazakhstan, Uzbekistan, Russia, Kyrgyzstan, Azerbaijan), a typology of abuse mechanisms, a risk map for banks and financial intelligence units, and recommendations for international regulators, including FATF, OFAC, EU FISMA, and major international financial institutions. The work is based on ARGA’s unique empirical database and demonstrates that in many jurisdictions AML/sanctions tools have evolved into a systemic instrument of pressure and selective enforcement.
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