The European Commission’s letter to Santa on December 22, 2021 included a wish for a directive restricting the use of shell companies to domicile assets or financial flows at letterbox locations across the EU at the stroke of a pen. When I reported on the contents of the “Unshell” draft legislation at the time, the focus was exclusively on tax avoidance – whether by multinationals or rich individuals. Two months later, Russia invaded Ukraine, triggering the largest wave of economic sanctions ever applied by the EU. And shell companies used by sanctioned oligarchs or Kremlin-controlled corporations popped up in a…

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