Case timeline
The 80 enforcement cases on this site laid out by year of first consequence, with the authority, outcome and techniques each one demonstrates.
- cases
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80
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2009–2026
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A case is placed in the year of its first dated consequence: the penalty, the plea or the designation. Where a case has no dated penalty it sits in the last year of the conduct. The amounts are the first penalty recorded for the case, in the currency it was imposed in, and are not converted or adjusted.
2026
- Rice Lake Weighing Systems: one email, no translation $61k. How do gaps in acquisition integration create sanctions exposure; third-country transshipment
- Citibank London: 970 payments, one missed prefix £4.7m. correspondent banking used to evade sanctions; ownership threshold structuring
- Sabre: a $200 test payment through a second bank £1.0m. third-country bank accounts and how are they used
- Adani Enterprises: 35 cargoes of LPG that were not Omani $275m. AIS manipulation and AIS spoofing; flag hopping; cargo origin blending; a front company; trade misinvoicing
- Deutsche Bank London: a screening list with no ownership data £165k. ownership threshold structuring
- Apple Distribution International: an ownership change nobody caught £390k. ownership threshold structuring
- TradeStation: two layers of geo-blocking, both down $1.1m. What happens when sanctions-screening controls go untested
- IMG Academy: tuition paid by third parties for two designated parents $1.7m. third-country bank accounts and how are they used
- Keystone Shipping: Russian bitumen via sham sales chains €250k. third-country transshipment; cargo origin blending; a front company
- Insurance against a risk the seller creates opaque marine insurance; cryptocurrency used to evade sanctions; stablecoin settlement and why does it matter for sanctions
- Lübeck: 16,000 deliveries to Russian defence companies alleged a front company
2025
- Exodus: support staff who suggested a VPN $3.1m. cryptocurrency used to evade sanctions
- Gracetown: payments for a designated oligarch's former company $7.1m. ownership threshold structuring; a front company
- IPI Partners: a legal opinion built on half the facts $11m. ownership threshold structuring; nominee directors and nominee shareholders; shell company layering
- ShapeShift: 17,183 exchanges with users in sanctioned countries $750k. cryptocurrency used to evade sanctions
- Fracht: a charter on a blocked Mahan Air aircraft $1.6m. a professional enabler
- A €62,000 car declared at €4,900 €3k. trade misinvoicing; third-country transshipment
- Interactive Brokers: six failures across one platform $12m. What happens when sanctions-screening controls go untested; ownership threshold structuring
- Harman: 'North Dubai' as a code for Iran $1.5m. third-country transshipment; dual-use re-export diversion
- Key Holding: found during due diligence for the next sale $609k. How do gaps in acquisition integration create sanctions exposure
- Unicat: Iran written as "I" in the emails $3.9m. third-country transshipment; a front company
- GVA Capital: managed through a nephew $216m. nominee directors and nominee shareholders; ownership threshold structuring; shell company layering; a professional enabler
- Herbert Smith Freehills Moscow: six payments in a rushed closure £465k. ownership threshold structuring
- Estonia: a media network kept running after it 'closed' €8k. a front company
- Haas: unlock codes for machines owned by blocked Russian entities $1.0m. dual-use re-export diversion; ownership threshold structuring
- Family International Realty: transferred to relatives $1.1m. ownership threshold structuring; nominee directors and nominee shareholders; shell company layering; a professional enabler
- Markom Management: an overpayment returned to a designated person £300k. a professional enabler
- Flighttime: a false end-user certificate aircraft parts procured in breach of sanctions; end-user certificate fraud; third-country transshipment; a front company
2024
- SkyGeek: a $669 refund to a newly designated UAE supplier $22k. aircraft parts procured in breach of sanctions
- C.H. Robinson: five subsidiaries not yet on the parent's screening $258k. a professional enabler; How do gaps in acquisition integration create sanctions exposure
- Aiotec: a polypropylene plant declared for Türkiye, delivered to Iran $15m. end-user certificate fraud; third-country transshipment
- Herbert Smith Freehills Moscow: six payments while closing the office £465k. a professional enabler
- Vietnam Beverage: alcohol to North Korea, paid by 17 firms $860k. third-country bank accounts and how are they used; correspondent banking used to evade sanctions
- State Street: redated invoices inside an acquisition $7.5m. How do gaps in acquisition integration create sanctions exposure; What happens when sanctions-screening controls go untested
- Mondo TV: paying a North Korean studio through a US company $538k. third-country bank accounts and how are they used
- SCG Plastics: Iranian resin with the origin 'Middle East' $20m. third-country transshipment; correspondent banking used to evade sanctions; trade misinvoicing
- EFG: blocked clients behind an omnibus account $3.7m. correspondent banking used to evade sanctions; a front company; omnibus securities accounts used to evade sanctions
- TGR Group: cash in one city, USDT in another stablecoin settlement and why does it matter for sanctions; hawala and how does informal value transfer work; cryptocurrency used to evade sanctions; a professional enabler; trade misinvoicing
- Netherlands: lab equipment exported through a web of firms a front company; dual-use re-export diversion
2023
- Nasdaq: an Iranian bank on the member list nobody read sanctions into $4.0m. How do gaps in acquisition integration create sanctions exposure
- Binance: a matching engine with no jurisdiction in it $969m. cryptocurrency used to evade sanctions
- Rotterdam: components invoiced to the Maldives €200k. third-country transshipment; dual-use re-export diversion
- Swedbank Latvia: a client banking from Crimea $3.4m. third-country bank accounts and how are they used; correspondent banking used to evade sanctions; shell company layering
- Murad: hidden from the acquirer, before and after the deal $3.5m. third-country transshipment
- British American Tobacco and the North Korea joint venture $509m. a front company; third-country bank accounts and how are they used; correspondent banking used to evade sanctions; shell company layering
- Wells Fargo: software built to host what the bank wouldn't process $30m. a professional enabler; What happens when sanctions-screening controls go untested
- Blender, Tornado Cash and Sinbad: designating the mixers mixers and chain hopping; cryptocurrency used to evade sanctions
- Lumber Marine and Ice Pearl: the first price cap designations price cap attestation fraud; opaque marine insurance; cargo origin blending
2022
- Danfoss: paid through a US bank's UAE branch $4.4m. third-country bank accounts and how are they used
- Bittrex: onboarding data collected and not screened $24m. cryptocurrency used to evade sanctions
- Toll Holdings: a freight forwarder's 2,958 payments $6.1m. a professional enabler; third-country transshipment; correspondent banking used to evade sanctions; a phantom shipment; How do gaps in acquisition integration create sanctions exposure
- Sojitz Hong Kong: dollar payments for Iranian-origin polyethylene $5.2m. third-country bank accounts and how are they used; cargo origin blending; correspondent banking used to evade sanctions; trade misinvoicing
2021
- Nordgas: re-exporting US pressure switches to Iran $950k. dual-use re-export diversion; end-user certificate fraud; third-country transshipment; a front company
- Bukit Muria Jaya: cigarette paper for North Korea, paid in dollars $1.0m. third-country transshipment; third-country bank accounts and how are they used
- UBAF: Syrian transfers booked inside, mirrored in dollars $8.6m. correspondent banking used to evade sanctions
2020
- Berkshire Hathaway: a Turkish subsidiary hid Iran sales $4.1m. third-country transshipment; a front company
- Essentra FZE: cigarette filters to North Korea through front companies $665k. a front company; third-country transshipment; third-country bank accounts and how are they used; end-user certificate fraud
- Standard Chartered UK: 70 loans to a Sberbank subsidiary £20m. third-country bank accounts and how are they used
2019
- MID-SHIP Group: payments connected to blocked vessels $872k. a ship-to-ship transfer; flag hopping; correspondent banking used to evade sanctions; a professional enabler
- UniCredit: a written guide to payments the US would not see $611m. correspondent banking used to evade sanctions; a front company
- Standard Chartered: 9,335 payments from accounts in Dubai $657m. third-country bank accounts and how are they used; a front company; correspondent banking used to evade sanctions; ownership threshold structuring
2018
- Epsilon Electronics: selling to a distributor that sold to Iran $1.5m. third-country transshipment; a front company; dual-use re-export diversion
- Halkbank, Zarrab and Atilla: oil revenue disguised as food gold and commodities used to settle sanctioned trade; HS code misclassification; correspondent banking used to evade sanctions; a front company; trade misinvoicing
2017
- CSE TransTel: a promise to its bank, broken in two months $12m. third-country bank accounts and how are they used
- ExxonMobil: eight documents signed with Igor Sechin $2.0m. ownership threshold structuring
- ZTE: front companies and an internal plan to keep supplying Iran $101m. a front company; dual-use re-export diversion; end-user certificate fraud; third-country transshipment
2015
2014
- BNP Paribas: the $963m correspondent banking settlement $964m. correspondent banking used to evade sanctions; third-country bank accounts and how are they used
- Fokker Services: 1,153 shipments of aircraft parts to Iran and Sudan $51m. aircraft parts procured in breach of sanctions; dual-use re-export diversion; third-country transshipment
- Bank of Moscow: Bank Melli Iran as 'BMI CJSC' $9.5m. correspondent banking used to evade sanctions
- Clearstream: one layer deeper in the custody chain $152m. shell company layering; third-country bank accounts and how are they used; correspondent banking used to evade sanctions; omnibus securities accounts used to evade sanctions
2012
- HSBC: Burma and Sudan, not just Iran $375m. correspondent banking used to evade sanctions
- Standard Chartered 2012: Sudan largest, all self-disclosed $132m. correspondent banking used to evade sanctions
- ING: 20,452 Cuba transactions, run from the branches $619m. correspondent banking used to evade sanctions; a front company