How sanctions evasion works, and how it gets caught.
A free reference on the techniques used to move money and goods across borders in defiance of restrictions — written entirely from the detection side. Every technique here is documented in published advisories, typology reports and enforcement records.
These are the last four actions the US Treasury published. Everything on this site is about how a company ends up in a notice like one of these.
2026-09-04 — Iran-related Designations; Issuance of Iran-related General License [IRAN]
2026-09-03 — Cuba Designations; Russia-related Designation Removal; Issuance of Amended Cuba General License [RUSSIA; CUBA]
2026-09-02 — Reminder to file the 2026 Annual Report of Blocked Property; Issuance of Amended Venezuela-related General Licenses and Frequently Asked Question [VENEZUELA]
2026-08-28 — Iran-related and Counter Terrorism Designations [IRAN; COUNTER TERRORISM]
The full feed, updated daily. The list itself carried 19,329 entries when last checked, including 1,007 digital currency addresses.
Start here
Six technique pages, one from each category, written to the standard the rest of the site works to: mechanics at the level a published typology report describes them, then the indicators, then the enforcement record.
- What is a front company? A front company is a business that trades normally but exists largely to hide another party's involvement in its transactions. The real activity is the cover; the concealed party is the point.
- What is trade misinvoicing? Trade misinvoicing is misstating the price, quantity or description of goods on trade documents, so that value moves across a border in a direction and an amount the paperwork does not admit.
- What is a ship-to-ship transfer? Transferring cargo directly between two vessels at sea, rather than through a port, so that the cargo changes hands where there is no port authority, no customs entry and no independent record.
- What is third-country transshipment? Routing restricted goods through an intermediate country so that the shipment reaching the restricted destination appears to originate somewhere the exporter would have supplied without question.
- How is correspondent banking used to evade sanctions? Using a chain of banks that each know only their own customer, so that a payment for a restricted party reaches a currency it could not access directly, without any bank in the chain seeing the whole transaction.
- How is cryptocurrency used to evade sanctions? Settling obligations in virtual assets so that value moves without a correspondent bank, a payment message or a screening system in the path, and without any institution able to block it in transit.
What is on this site
- Techniques
- 25 explained
- Red-flag indicators
- Attributed library
- Glossary
- 79 terms
- Enforcement cases
- 27 documented
- Penalty record
- $7.9bn since 2009
- Designations feed
- Updated daily
If you are new to this
- What are sanctions and how do they actually work? Sanctions are legal restrictions on dealings with a named person, entity, sector or country, imposed by a state or international body and enforced against anyone within that authority's jurisdiction.
- How does someone get on a sanctions list? A designation is a published administrative decision naming a target and stating the authority for listing it, which triggers the restrictions attached to that programme from the moment of publication.
- What is the 50 percent rule, and why is it different in the UK and EU? OFAC treats any entity owned fifty per cent or more in aggregate by blocked persons as itself blocked, whether or not it is named. UK and EU measures instead catch entities owned or controlled.
- What are secondary sanctions? Secondary sanctions threaten non-US persons with loss of access to the US market or financial system for conduct that is lawful where it happens, rather than prohibiting that conduct directly.
- Which agencies actually investigate and penalise sanctions violations? Financial sanctions are enforced by treasury agencies such as OFAC and OFSI, export controls by agencies such as BIS, and criminal conduct by prosecutors, frequently all three in parallel.
- How do investigators actually find sanctions evasion? Almost always by reconciling records held by different parties. Individual documents in an evasion scheme are internally consistent; what fails is the comparison between them.
- What is the difference between sanctions and export controls? Sanctions restrict dealings with a party; export controls restrict the movement of an item by reference to what it is, where it is going and what it will be used for. Screening a counterparty satisfies neither obligation for the other.
Common questions
What is sanctions evasion?
Sanctions evasion is conduct designed to complete a transaction that a sanctions or export control measure prohibits, usually by concealing the identity of a restricted party, the origin or destination of goods, or the route taken by a payment.
Is describing how sanctions evasion works the same as instructing it?
No. This site describes mechanics only at the level published in official advisories, FATF typology reports, UN Panel of Experts reports and court filings, and every technique page ends on how the method is detected and what the enforcement record shows.
Who enforces sanctions?
Financial sanctions are enforced by treasury agencies such as OFAC in the United States and OFSI in the United Kingdom, export controls by agencies such as the Bureau of Industry and Security, and criminal conduct by prosecutors. Large cases usually involve all three in parallel.
More on the editorial approach, and how corrections are handled, is on the about page. Every dataset used here is listed with its licence and last fetch date on the sources page.