What is proliferation financing?

Proliferation financing is broadly defined as the provision of funds or financial support used to develop, acquire, or transfer weapons of mass destruction (WMDs) and their delivery systems. These can include nuclear, biological, radiological and chemical weapons—tools of immense devastation that threaten global security.

This makes proliferation financing distinct from money laundering, which disguises the origins of illicit funds, or terrorist financing, which directs often legitimate funds to ideological violence.

The UK, aligning with FATF standards, has put in place sanctions to help prevent our financial systems from enabling WMD proliferation. With these come rigorous compliance requirements for regulated professionals in the property, legal, TCSP and accountancy sectors are now directly responsible for identifying and mitigating its risks.

Why proliferation financing is a growing concern

Proliferation financing is more than a distant geopolitical issue. The Financial Action Task Force (FATF) has identified proliferation financing as a priority area.

The best way to show why is by using real-life examples of proliferation financing:

1. Property acquisition linked to proliferation financing

In July 2024, a property transaction in the UK raised red flags when the purchasing company was traced back to an engineering firm in a high-risk jurisdiction. This scenario matched known typologies of entities under investigation for proliferation financing.

2. Iranian UAV procurement network

In December 2023, an Iranian national and a previously sanctioned Chinese individual were charged with procuring U.S.-manufactured dual-use electronics intended for un-crewed aerial vehicles (UAVs) used by Iran’s Islamic Revolutionary Guard Corps (IRGC).

The pair’s operation involved front companies across Iran, Malaysia, Hong Kong and Indonesia to obscure the end destination of these goods. Notably, a French company was unwittingly involved, purchasing electronic items from the U.S., which were then diverted to Iran via Hong Kong.

3. Arms dealer leverages EU human rights laws

A recent case involving an Iranian arms dealer, who successfully avoided deportation from the UK by leveraging EU human rights laws, shows how close to home proliferation financing can be. The individual was allegedly involved in procuring and supplying weapons components in violation of international sanctions, and has been identified as a security risk.

How you might spot proliferation financing

Proliferation financing can occur in a multitude of ways, taking advantage of gaps in our financial ecosystem. Professionals in regulated sectors play a key role in identifying and addressing these risks, using their business’ anti-money laundering and counter-proliferation financing (CPF) measures.

A key focus for counter-proliferation financing is the implementation of UK and UN sanctions regimes on the Democratic People’s Republic of Korea, Iran and also chemical weapons activity.

You must consider if your clients have any dealings with countries that are subject to sanctions that restrict the proliferation of weapons of mass destruction such as the Democratic People’s Republic of Korea (DPRK) or Iran. Or if your clients have dealings with countries that are suspected of using or seeking to acquire weapons of mass destruction such as Syria or countries that share a porous border with any such countries.

The sanctions measures apply to anyone in the UK’s jurisdiction, action taken by a UK national outside of the UK and to companies incorporated in the UK.

Trade-based financial schemes

One of the most common methods of proliferation financing is through trade-based financial schemes. False invoices, over- or under-valued goods, or misdeclared end uses can all mask the movement of funds for proliferation activities.

Use of dual-use goods

Dual-use goods, which have both civilian and military applications, are frequently exploited (as the real-life examples above show). For example, chemicals or electronics with legitimate industrial uses can also be diverted for WMD production.

Shell companies and front organisations

Shell companies and front organisations are often created to conceal the true beneficiaries and purposes of transactions and commonly used in money laundering cases. These entities obscure the money trail, making it harder to detect illicit activities.

Exploitation of alternative financial sources

Proliferation financiers may exploit correspondent banking networks, offshore accounts, or even smaller, less regulated financial institutions to facilitate anonymous transactions. Industries like cryptocurrency or crowdfunding sites have also been shown to vulnerable to exploitation in terrorist financing cases.

The risks for regulated professionals

Criminals and sanctioned entities are using increasingly sophisticated methods to evade detection. Regulated professionals can become unwittingly involved in their schemes. As a professional in the property, legal, TCSP and accountancy sectors, you play a pivotal role in preventing financial systems from being exploited for proliferation financing.

Property transactions

The property sector remains an attractive target for criminals involved in proliferation financing, particularly due to the high-value nature of real estate transactions and the ability to disguise illicit funds. According to the UK’s National Risk Assessment (NRA) of Proliferation Financing (2021), property can be used to:

• Store value gained from proliferation-related activities.
• Launder illicit proceeds linked to dual-use goods or sanctioned entities.
• Facilitate anonymised transactions through third-party purchasers or corporate structures.

The key risks are:

1. Lack of transparency in ownership: Properties purchased via shell companies or trusts obscure the ultimate beneficial owner (UBO), making it harder to identify illicit funds.
2. High-value cash transactions: Suspicious high-value purchases without clear financial explanations can indicate links to proliferation financing.
3. Overseas purchasers: Transactions involving buyers from high-risk jurisdictions subject to sanctions require additional scrutiny.

Legal services

Lawyers are uniquely vulnerable to exploitation due to their involvement in complex corporate and financial structures. The Law Society Guidance on Proliferation Financing highlights how legal professionals can unwittingly enable illicit activities by:

• Creating trusts and shell companies: These structures can conceal the identities of individuals or entities facilitating proliferation.
• Managing funds or assets: Legal professionals may unknowingly handle transactions that involve sanctioned goods or entities.
• Providing advice on international trade or financial transactions: Lawyers engaged in cross-border services face heightened risks when working with clients from jurisdictions subject to international sanctions.

The key risks are:

1. Complex ownership chains: Layered corporate structures can be used to obscure connections to sanctioned entities or individuals.
2. Cross-border transactions: Payments or asset transfers involving multiple jurisdictions raise proliferation financing red flags, particularly where dual-use goods are concerned.
3. Client secrecy: If clients insist on anonymity or fail to provide clear reasons for certain transactions, these could indicate illicit intent.

Accountancy services

Accountants play a central role in managing, reporting, and verifying financial transactions, making them a target for those seeking to disguise proliferation financing. The Accountancy AML Guidance issued by the Consultative Committee of Accountancy Bodies (CCAB) stresses that accountants are at risk when:

• Auditing or managing accounts linked to dual-use goods or sanctioned clients.
• Handling complex international transactions involving jurisdictions with weak AML controls.
• Failing to identify red flags in financial records that suggest illicit fund movements.

The key risks are:

1. Overseas accounts and high-value transactions: Proliferation networks often use complex financial transfers to obscure illicit purposes.
2. Unusual financial patterns: Large, frequent transfers with no commercial justification or linked to dual-use goods require further investigation.
3. Inadequate due diligence: A failure to properly understand a client’s business activities and sources of funds can expose accountants to risks.

Trust and company service providers (TCSPs)

TCSPs are at significant risk of being exploited for proliferation financing due to their role in setting up and managing legal entities. These services are often used to create complex corporate structures, shell companies and trusts that obscure the identities of those involved, enabling bad actors to facilitate illicit financial flows and evade international sanctions.

The key risks are:

1. Shell companies and nominee directors: Shell companies, often established in jurisdictions with weak AML frameworks, are used to hide the identities of sanctioned individuals or entities. By appointing nominee directors or shareholders, bad actors can further distance themselves from the entities, making detection harder.
2. Complex ownership structures: Layered ownership chains involving multiple jurisdictions can obscure links to illicit proliferation activities. These structures are deliberately complex, making it challenging to identify the ultimate beneficial owner (UBO).
3. Unexplained changes in control or management: A sudden change in directors, shareholders, or trustees without a clear rationale can signal attempts to hide proliferation activities or move illicit funds undetected.
4. Offshore jurisdictions: Trusts or companies established in offshore financial centres with limited transparency are often used to transfer funds to sanctioned regions or acquire dual-use goods.

Warning signs to watch out for across all sectors

If you’re on top of your AML compliance, you should have the process in place to spot warning signs like these, which could indicate proliferation financing risks:

• Clients based in or trading with jurisdictions subject to international sanctions.
• Transactions involving dual-use goods without clear end-user documentation.
• Complex corporate structures or offshore entities used to obscure the UBO.
• High-value transactions with no commercial or legal justification.
• Payments involving multiple intermediaries or routed through high-risk jurisdictions.

As a regulated professional, you’re legally obliged to report suspicious activities like these under the Proceeds of Crime Act 2002 (POCA) and the Terrorism Act 2000. Suspicious Activity Reports (SARs) must be submitted to the National Crime Agency (NCA) if you suspect transactions or clients are linked to proliferation financing.

Ensure that your reports are thorough, including details such as transaction records, involved parties, and evidence of potential wrongdoing.

Your team plays a pivotal role in detecting and reporting proliferation financing. Regular training ensures they are aware of the latest risks, red flags, and compliance measures. Tailor training sessions to focus on the specific risks faced by your sector.

Having a watertight AML structure will help you fulfil these reporting responsibilities. This is where AMLCC comes in.

How amlcc.com helps you stay compliant

When it comes to identifying and mitigating proliferation financing risks, you need robust tools that simplify compliance processes without compromising on accuracy.

We offer a comprehensive suite of features designed specifically for UK property, legal, TCSP and accountancy professionals, helping you meet your anti-money laundering (AML) and counter-proliferation financing (CPF) obligations with confidence.

• Stay compliant with UK AML regulations and FATF standards.
• Identify and mitigate risks associated with proliferation financing.
• Detect and report suspicious activities efficiently.
• Train your team to recognise red flags and understand their compliance responsibilities.

The threat of proliferation financing is real, but with the right measures in place you can play a pivotal role in mitigating its impact.