Deadline: 30-Jul-25
Applications are now open for the Enforcing Sanctions on China and Russia Program.
Goals and Objectives
- To help partners identify these increasingly complex sanctions evasion strategies and take action to stop them, ISN/CTR provides expert resources and technical engagements to identify and avoid transactions with designated Chinese and Russian entities and their associated networks. As the evasion landscape has evolved to become more complex, engagements have expanded from traditional compliance, investigatory, and enforcement bodies to include strategy & operations, sales departments, business owners, and investors, etc.
- ISN/CTR is specifically interested in tailored programs and resources that are designed to empower public and private sector entities to strengthen sanctions compliance. Through detailed instruction and open-source data research tools, ISN/CTR will reduce proliferation risks and disrupt sanctions evasion entities and networks in the following areas:
- Private Sector:
- Bank and Non-bank Financial Institutions
- Designated Non-Financial Business and Professions
- Dual-use Manufacturing and Technology Startups & Businesses
- Trade & Logistics Sectors
- Public Sector, including enforcement, investigatory, and regulatory bodies
- Project Goal
- Engage foreign audiences on identifying and taking action against complex sanctions evasion entities and networks. Projects should be cost effective and create self-sustaining improvements in sanctions compliance and enforcement.
- Objectives
- Targeted Financial Sector Sanctions Engagements: Sanctions evasion tactics used by China and Russia rely upon continued access to the global financial market to facilitate acquisition of proliferation-sensitive goods and technologies and support onward proliferation through illicit trade networks. These programs will engage financial private sector entities to provide technical training and tools in order to improve compliance with U.S. and other international sanctions regimes imposed on U.S. adversaries:
- Objective: Plan and organize technical trainings and follow-on private consultations on sanctions regimes that will bring together 20-50 stakeholders per event. The events should aim to reach small and medium sized firms, with weaker compliance systems, and should focus on improving due diligence, conducting investigations, demonstrating regulator data-sharing, highlighting risks, etc.
- Objective: Bring timely, relevant, and applicable case studies, using open-source information to the private sector that show active sanctions evasion exposure within the jurisdiction. Organizers should analyze audiences prior to engagements to tailor materials and case-studies to reach action-oriented results. Organizers can provide access to tools for participants following the engagement.
- Objective: Use commercially available and open-source data to develop and disseminate reports that help partners identify beneficial ownership structures, subsidiaries, lenders, financiers, and other links to sanctioned or prohibited entities.
- Objective: Deliver trainings that build on, and expand beyond, what ISN/CTR has offered to-date by tailoring to new regulatory developments, compliance guidance, countries of emerging risk, and links to sanctioned or prohibited entities.
- Objective: Plan and organize trainings for smaller groups that focus on improving private sector coordination with the public sector, including the relevant authorities and regulators.
- Objective: Plan and organize partnerships with key stakeholders which will facilitate ongoing training and assistance over the course of the project period of performance. Implement programs to provide regular access to technical experts and tools for stakeholders to support their ongoing development of strong sanctions compliance frameworks, investigations, and risk-mitigation processes.
- Objective: Provide access to open-source tools and experts who enable analysis and investigation of large datasets that show where and how global trade and financial networks are manipulated by China and Russia to evade nonproliferation sanctions. Further, to provide data and analyses on types of goods, trade volumes, and entities involved in illicit procurement networks. Turn these analyses into actionable reports for non-technical internal and external audiences that highlight violations of sanctions and/or risks indicating potential violations.
- Objective: Provide access to open-source tools and experts who enable analysis and investigation of entities, individuals, vessels, and aircraft likely associated with evasion of nonproliferation sanctions by China and Russia. Turn these analyses into actionable reports for non-technical internal and external audiences that highlight violations of sanctions, networks of enablers, and risk typologies present in evasion tactics.
- Counter Private Sector Sanctions Evasion: Chinese and Russian actors work to exploit dual-use advanced technology and manufacturing sectors to support their own military capabilities and advance their weapons programs. ISN/CTR’s capacity-building work looks to engage key private sector stakeholders within the dual-use advanced technology and manufacturing sectors to counter this activity. Key stakeholders could include startups & businesses developing advanced materials, software, machine tools, and microelectronics.
- Objective: Support targeted, private consultations with advanced technology and manufacturing firms to help de-risk supply chains away from sanctioned or prohibited networks.
- Objective: Plan and organize capacity building and technical events that will bring together 20-50 stakeholders per event. The events should engage industry partners (suppliers, shippers, intermediaries, other supply-chain stakeholders) to demonstrate areas of exposure to prohibited Chinese and other malign entities and the reputational and sanctions risks associated with transacting with designated entities in these assets/sectors.
- Objective: Plan and organize small, targeted events that engage regulatory bodies, trade associations, and other appropriate sector representatives on the need for strong compliance, control tools, and due diligence to ensure maximum transparency when addressing Chinese and other malign entities sanctions evasions tactics in the sector.
- Counter Trade & Logistics Sanctions Evasion
- Chinese and Russian actors continue to leverage vessels, aircraft, and ground transportation services to move technology and goods that help them circumvent sanctions. While many jurisdictions have taken steps to de-risk, sanctions evaders continuously seek out new jurisdictions, routes, registries, shippers, and distributors with weak compliance standards to enable their illicit activity. ISN/CTR’s national security programming works to engage key public and private sector stakeholders to counter this illicit trade and logistics sanctions circumvention in the maritime, aviation, and ground transportation sectors.
- Objective: Plan and organize capacity building and technical events that will bring together 20-50 stakeholders per event. The events should provide both public and private maritime, aviation, and ground transportation stakeholders with timely and in-depth investigative support to counter Chinese and Russian entities sanctions evasion activity through international trade and logistics channels.
- Objective: Plan and organize capacity building and technical events that target the following stakeholders: partner governments, chartering services/owners, flag registries, banks, insurance companies, port operators and other maritime stakeholders to shed light on findings/behaviors of suspicious vessels and associated maritime entities.
- Objective: Events should focus on improving due diligence and supporting investigations that address challenges that can include, ship-to-ship transfers; obfuscation of transshipment information; vessel location manipulation; forged bills of lading/cargo manifests; turning away, addressing, or seizing a designated vessel; etc.
- Chinese and Russian actors continue to leverage vessels, aircraft, and ground transportation services to move technology and goods that help them circumvent sanctions. While many jurisdictions have taken steps to de-risk, sanctions evaders continuously seek out new jurisdictions, routes, registries, shippers, and distributors with weak compliance standards to enable their illicit activity. ISN/CTR’s national security programming works to engage key public and private sector stakeholders to counter this illicit trade and logistics sanctions circumvention in the maritime, aviation, and ground transportation sectors.
- Targeted Public Sector Sanctions Outreach: Russian and Chinese actors’ sanctions evasion schemes seek to heavily infiltrate a number of sectors (financial, industry, maritime, aviation, logistics, etc.) that various public sector authorities and regulators are responsible for monitoring and overseeing. ISN/CTR collaborates with these organizations to share knowledge about sanctions regulations, build trust between the public and private sector, and ultimately strengthen compliance and enforcement practices. These programs will engage public sector entities through the following objectives:
- Objective: Plan and organize technical consultations and private meetings for private sector policy and enforcement entities. These engagements will be more targeted than a large workshop. These public sector engagements should be implemented as technical engagements/exchanges where organizers engage organizations or agencies individually, instead of as part of a larger training. These technical consults should aim to reach investigatory bodies (to include financial intelligence units, law enforcement, and regulators) to train them to identify sanctions evasion networks linked to Chinese and Russian actors. In some cases, there is benefit to including public sector audiences together with private sector stakeholders to promote strong public/private sector partnerships, improve understanding of regulations, and foster robust communication on topics of sanctions compliance and enforcement.
- Objective: Plan and organize partnerships with key public sector stakeholders which will facilitate ongoing training and assistance over the course of the project period of performance. Implement programs to provide regular access to technical experts and tools for stakeholders to support their ongoing development of strong sanctions compliance frameworks, investigations, and risk-mitigation processes.
- Objective: Provide access to open-source tools and experts who enable analysis and investigation of large datasets that show where and how global trade and financial networks are manipulated by China and Russia to evade nonproliferation sanctions. Further, to provide data and analyses on types of goods, trade volumes, and entities involved in illicit procurement networks. Turn these analyses into actionable reports for non-technical internal and external audiences that highlight violations of sanctions and/or risks indicating potential violations.
- Objective: Provide access to open-source tools and experts who enable analysis and investigation of entities, individuals, vessels, and aircraft likely associated with evasion of nonproliferation sanctions by China and Russia. Turn these analyses into actionable reports for non-technical internal and external audiences that highlight violations of sanctions, networks of enablers, and risk typologies present in evasion tactics.
- Targeted Financial Sector Sanctions Engagements: Sanctions evasion tactics used by China and Russia rely upon continued access to the global financial market to facilitate acquisition of proliferation-sensitive goods and technologies and support onward proliferation through illicit trade networks. These programs will engage financial private sector entities to provide technical training and tools in order to improve compliance with U.S. and other international sanctions regimes imposed on U.S. adversaries:
Funding Information
- Award amounts: Awards may range from a minimum of $250,000 to a maximum of $5,000,000(approximately)
- Total available funding: $19,500,000 pending availability of funds
Duration
- Length of performance period: 12-24 months
Eligibility Criteria
- The following organizations are eligible to apply:
- U.S. for-profit organizations or businesses;
- U.S.-based non-profit/non-governmental organizations with or without 501(c) (3) status of the U.S. tax code;
- U.S.-based private, public, or state institutions of higher education;
- foreign-based non-profit organizations/non-government organizations (NGO);
- Federally Funded Research and Development Centers (FFRDCs); Public International Organizations (PIO);
- Foreign Public Entities (FPE); and foreign-based institutions of higher education.
For more information, visit Grants.gov.
