Notes
Analysis and data notes: original work on the datasets this site ingests, and methodology write-ups for anything it computes itself.
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This is not a blog in the sense of commentary on the news. It is where original analysis of the datasets this site ingests goes, along with the methodology notes that any such analysis owes its readers. Everything here is dated because, unlike the technique pages, it is about a moment.
- FinCEN's $9 billion of Iranian shadow banking, unpacked FinCEN counted about $9 billion of reported activity linked to Iranian shadow banking in 2024. Dubai and Hong Kong carry most of it, 166 companies account for 95 per cent, and the UK and Oman appear in smaller roles.
- OFSI's other fourteen: what the smaller penalties show Fourteen of OFSI's 21 published actions have no case page here. Read one by one, none involves concealment. They turn on borrowed checks, identity data in hand, staffing gaps, misreadings of the law and unanswered letters.
- The bank settlements of 2009 to 2015, counted Nine bank settlements of $100 million or more, all between 2009 and 2015, make up 46 per cent of everything OFAC has published. In five of the six with a programme breakdown, the largest share was not Iran.
- The notice, read closely: IPI Partners' missing facts OFAC's December 2025 release on IPI Partners is about a compliance team that asked the right question after a designation and got the wrong answer, because it never told its own lawyers what it knew.
- What the US Consolidated Screening List contains The US screening list bundles 26,146 entries from twelve lists across three agencies. The OFAC SDN list is 74% of it; the Commerce Entity List has about as many Russian entries as Chinese ones.
- What OFSI's 21 published enforcement actions look like Eighteen monetary penalties worth about £28.1m and three disclosures without one. Banks are six of the 21 actions and 91% of the money. The median penalty is about £150,000, and most actions come from 2025 and 2026.
- The notice, read closely: FTI Consulting and six unpaid invoices OFAC's June 2026 release on FTI Consulting is about a payment structure built to avoid dealing with a sanctioned bank, and how the invoices still counted. The settlement was twice the base penalty, which the release explains.
- What the published OFAC penalty record actually looks like Every civil penalty OFAC has published since 2009, read as a single dataset. The distribution is far more lopsided than the headline cases suggest, and the sectoral composition has changed completely.
- Where machinery exports to Russia went after 2022 Three small economies on Russia's border began exporting machinery to it at between six and twenty-three times their previous rate in the year direct routes closed. This is what that looks like in the two countries' own published figures.
- How we compute mirror statistics, and what they cannot tell you The exact query, filters and assumptions behind the trade comparisons on this site, published so that the numbers can be checked, reproduced and disagreed with.