Is the concern around proliferation financing getting worse? Businesses want to know

Proliferation financing (PF) is becoming a bigger problem for businesses in the UK and EU, and the consequences of getting caught up in it can be devastating. 

What exactly is proliferation financing?

Essentially, it’s when money, goods or services are used, knowingly or unknowingly, to support the development of weapons of mass destruction (WMDs). Think nuclear, chemical, or biological weapons, and the technology needed to deliver them. While this might sound like something only governments and intelligence agencies deal with, the reality is that everyday businesses can easily get caught in the crossfire.

Why is this a bigger deal now?

A few key reasons:

  • Sanctions are stricter than ever – Countries like North Korea, Iran, and Russia are facing heavy sanctions, and as restrictions increase, so do their efforts to work around them. These nations are using ever more sophisticated financial networks to keep money moving and fund their operations.
  • Businesses are more globally connected – Supply chains are sprawling, financial transactions happen at lightning speed, and companies deal with partners across multiple jurisdictions. It’s easier than ever to unknowingly engage with bad actors.
  • Tech is a game changer – The rise of cryptocurrencies and fintech means that funds can move in ways that are harder to track. North Korea, for example, has been linked to crypto hacks and ransomware attacks, using stolen digital assets to fund its weapons programs.
  • Stronger enforcement – Regulators and financial authorities have stepped up their efforts to crack down on PF. The UK and EU have introduced stricter laws that require businesses to actively assess and mitigate their PF risks. If you fail to do so, you could be in serious trouble.

Is it hard to get caught up in PF? No

Many companies don’t even realize they’re involved in proliferation financing until it’s too late. Here’s how it can happen:

  • Your company might be selling completely legal items, like semiconductors, drones, or industrial chemicals, only to find out later that they were diverted to a weapons program. These products have both civilian and military applications, making them a key target for sanction evasion schemes.
  • If you don’t have strong due diligence processes, you could end up working with a front company that’s secretly connected to a sanctioned entity. These firms often look legitimate on paper but exist solely to disguise illicit activities.
  • TTechniques like fake invoices, under- or over-invoicing, and false documentation allow bad actors to move money through international trade undetected. Even reputable businesses can be used as intermediaries.

It happens

These aren’t just hypothetical risks. There have been real-world examples of businesses getting caught up in proliferation financing without even realizing it:

  • A British insurance company found itself in hot water when it was revealed that it had insured vessels involved in smuggling sanctioned goods for North Korea. The company had no idea at the time, but that didn’t stop regulators from cracking down.
  • A European electronics firm sold high-tech equipment to a Southeast Asian company, thinking it was for civilian use. Later, authorities discovered that the goods had been rerouted to a facility developing nuclear weapons. The company faced heavy penalties and reputational damage.

What can businesses do to mitigate their risks?

The good news? You can take steps to protect your company from getting caught up in proliferation financing:

Screen your transactions – Regularly check customers and suppliers against global sanctions lists, including those from the UN, UK, EU, and US .

Conduct risk assessments – Regulators expect businesses to evaluate their exposure to PF and put safeguards in place.

Implement enhanced due diligence – High-risk transactions and customers require extra scrutiny. Dig deeper before entering into business relationships.

Train employees – Make sure your team knows what to look for and understands how to spot red flags.

Stay updated on regulations – Sanctions and compliance requirements are constantly evolving. Keep up or risk falling behind and paying a high price.

Proliferation financing isn’t just a problem for governments and banks. It’s something every internationally connected business should be aware of. With tighter sanctions, evolving tactics from bad actors, and stronger enforcement from regulators, companies in the UK and EU need to take PF risks seriously.

A little vigilance now could save you from fines, legal trouble, and reputational damage down the line. Stay informed, stay compliant, and make sure your business doesn’t become a part of the problem.

Join our free webinar to understanding and mitigating proliferation financing and sanctions risks on 5 March 2025 at midday UK time.

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GDPR added a significant compliance burden on DPOs and data processors. Data breaches must be reported to the authorities within 72 hours, each new data processing activity needs to be documented and Data Protection Impact Assessments (DPIA) must be carried out for processing that is likely to result in a high risk to individuals. Penalties for breaching GDPR can reach into the tens of millions of Euros.

GDPR added a significant compliance burden on DPOs and data processors. Data breaches must be reported to the authorities within 72 hours, each new data processing activity needs to be documented and Data Protection Impact Assessments (DPIA) must be carried out for processing that is likely to result in a high risk to individuals. Penalties for breaching GDPR can reach into the tens of millions of Euros.

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How are you managing your GDPR compliance requirements?

GDPR added a significant compliance burden on DPOs and data processors. Data breaches must be reported to the authorities within 72 hours, each new data processing activity needs to be documented and Data Protection Impact Assessments (DPIA) must be carried out for processing that is likely to result in a high risk to individuals. Penalties for breaching GDPR can reach into the tens of millions of Euros.

GDPR added a significant compliance burden on DPOs and data processors. Data breaches must be reported to the authorities within 72 hours, each new data processing activity needs to be documented and Data Protection Impact Assessments (DPIA) must be carried out for processing that is likely to result in a high risk to individuals. Penalties for breaching GDPR can reach into the tens of millions of Euros.

How are you managing your GDPR compliance requirements?

GDPR added a significant compliance burden on DPOs and data processors. Data breaches must be reported to the authorities within 72 hours, each new data processing activity needs to be documented and Data Protection Impact Assessments (DPIA) must be carried out for processing that is likely to result in a high risk to individuals. Penalties for breaching GDPR can reach into the tens of millions of Euros.

GDPR added a significant compliance burden on DPOs and data processors. Data breaches must be reported to the authorities within 72 hours, each new data processing activity needs to be documented and Data Protection Impact Assessments (DPIA) must be carried out for processing that is likely to result in a high risk to individuals. Penalties for breaching GDPR can reach into the tens of millions of Euros.