Flowers, Freight & Forbidden Goods: A Global Sanctions Evasion Case
ACSS Webinar

CSS Credits: 1.25
Duration:
75 minutes
Speakers:
- Ms. (Dipl. Ing.) Tatjana Dobrovolny | Raiffeisen Bank International Group
- Sandra Ott | KLM Cargo
Moderator:
Ivy Llena, Sanctions Training Coordinator, ACSS
Date:
Time:
- 10:00 AM – 11:15 AM NYC
- 03:00 PM – 04:15 PM London
- 04:00 PM – 05:15 PM Amsterdam
Description:
This session presents a realistic, end-to-end case study showing how legitimate global trade can be exploited to circumvent sanctions, export controls, and trade finance restrictions.
Participants will follow a fictitious but highly plausible trade cycle in which ordinary commercial goods are used as cover for the movement of high-priority, battlefield-relevant items, while return flows exploit tariff differentials and weaknesses in trade finance controls. The case connects export licensing, logistics, maritime risk, banking, and AML/CTF oversight into one coherent narrative.
Through decision points and audience polls, participants will be challenged to identify red flags, assess risk, and decide when routine trade crosses into illicit activity.
Highlights of the webinar will include:
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Understand how sanctions evasion works in practice, across air, sea, and financial channels
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Recognize deceptive shipping and documentation patterns, including switch B/Ls, HS code drift, transshipment abuse, and ghost-fleet indicators
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Learn how high-priority items (HPI) can be concealed within non-sanctioned cargo
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Identify trade-based money laundering and tariff-evasion typologies linked to return flows
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Gain practical insights into what different authorities and institutions should do at each stage of the trade cycle
The session is designed for professionals in export controls, customs, logistics, shipping, banking, AML/FIU functions, and supervisory authorities, and focuses on actionable lessons rather than theory.
Certificate of Attendance:
All active ACSS members will be able to download the certificate from the Learning Management System (under the achievements tab).
Event Registration
Members of the Association
This webinar is included in your membership
and you will be sent login details by email a
day before the webinar.
If you would like to register for the webinar
in advance, so that it is entered into your calendar.
Non Members of the Association
Speakers

Ms. (Dipl. Ing.) Tatjana Dobrovolny
Senior Expert Compliance Programs and Systems Solutions
Raiffeisen Bank International Group
Tatjana is the senior advisor for design and implementation of global RBI Group standards, procedures, and efficient and effective IT systems with focus on innovative solutions. She is also a member of the advisory board of the Association of Certified Sanctions Specialists (ACSS) and member of the SWIFT Financial Crime Compliance Advisory Group (FCC-AG).
Tatjana is with Raiffeisen Compliance for almost 20 years serving also in sensitive data analytics and forensic investigations, having a degree in Electrical Engineering and Computer Science from the University of Electrical Engineering in Belgrade. Before joining RBI, Tatjana worked for almost 10 years in the IT development as a program manager for the implementation of a banking product for reconciliation of Nostro payment and custodial accounts.

Sandra Ott
Security & Customs Manager
KLM Cargo
Currently serving as Security & Customs Manager at KLM Cargo, Sandra plays a pivotal role in ensuring compliance with international regulations. She is the primary point of contact for all sanction-related matters, advising on complex regulatory frameworks and their impact on cargo operations. Her strategic approach helps mitigate risks while maintaining operational efficiency.
Sandra is committed to continuous professional development. Since 2023, she has been actively involved with the Association of Certified Sanctions Specialists (ACSS). In 2024, she further solidified her expertise by earning the Certified Sanctions Specialist (CSS) designation, demonstrating her deep understanding of international sanctions and trade compliance.
Her responsibilities extend beyond regulatory compliance; she also collaborates closely with internal teams and external stakeholders to implement best practices in security, customs procedures, and risk management. Sandra’s proactive approach ensures that KLM Cargo remains ahead of evolving industry regulations, reinforcing its reputation as a leader in air cargo compliance.
Moderator

Ivy Llena
Sanctions Training Coordinator
ACSS
Ivy Llena has over 14 years of experience in the learning and development field, providing capacity-building and professional development programs for corporate and social service agencies in the US and the Philippines.
Before joining ACSS, she was a program director at a non-profit organization in the Philippines, where she co-designed and co-implemented economic empowerment programs and services for survivors of human trafficking and their families. Ivy also served at the Social Policy Institute at Washington University in St. Louis, where she led and contributed to inclusive economic growth initiatives.
Customer Testimonials
“I really appreciated the detail and references on the slides, very helpful”.
“Great job. Very informative”.