Caroline Walka


On 20 February 2024, the financial intelligence agencies of Canada (FINTRAC), Germany (FIU DE) and the Netherlands (FIU-NL) released a joint advisory regarding illegal procurement of dual-use goods by Russian end-users (Joint Advisory). Although primarily addressed to entities reporting under each country’s respective anti-money laundering (AML) regime, the Joint Advisory also is a useful resource for other companies seeking to comply with sanctions and export controls more generally, as it seeks to provide additional guidance…