Sanctions Evasion Reference

Corrections log

Every factual error found on this site after publication, what the page said, what the source says, and where it was fixed. 12 errors are recorded so far, all found by checking pages against the primary documents.

errors corrected

12

entries

16

send one

corrections@sanctionsevasion.org

reviewed

2026-09-20

Cite this page
APA 7 
Sanctions Evasion Reference. (2026, September 20). Corrections log. https://sanctionsevasion.org/corrections/
Chicago 
Sanctions Evasion Reference. “Corrections log.” Last reviewed September 20, 2026. https://sanctionsevasion.org/corrections/.
BibTeX 
@misc{ser-corrections,
  author = {{Sanctions Evasion Reference}},
  title  = {Corrections log},
  year   = {2026},
  note   = {Last reviewed 2026-09-20},
  url    = {https://sanctionsevasion.org/corrections/}
}

The date is when this page was last reviewed, not when it was first published.

A page about detection should show its own failures. When a claim on this site turns out not to be supported by the document it cites, the page is corrected in place, and the correction is recorded here in the same terms: what was said, what the source says, which pages changed. Corrections are not made silently, and older entries are not removed.

Most entries below were found by a deliberate audit that downloaded the cited documents and checked each claim against them, not by readers. The audit changed how the site works: indicators and technique prose now carry verbatim source quotes that the build checks.

  1. 20 September 2026, Error corrected

    The OFSI penalty note gave the wrong median

    The page said
    The note gave the median OFSI monetary penalty as about £98,000.
    The source says
    Recomputed from the 18 penalties that carry an amount, the median is £149,545.50, which the note now gives as about £150,000.
    Source
    This site's OFSI dataset, recomputed 2026-09-20
    Pages
    /blog/what-21-ofsi-penalties-look-like/

  2. 20 September 2026, Error corrected

    The OFAC penalty note said findings of violation do not appear in the dataset; five do

    The page said
    The note said findings of violation without a monetary penalty do not appear in the dataset, described the median penalty as 'in the tens or low hundreds of thousands of dollars', and said the largest handful of settlements exceeded the entire remainder.
    The source says
    Five of the 283 rows are findings of violation, listed by OFAC with no monetary amount (for example MidFirst Bank, 2022, and Mashreqbank, 2021). Across the 278 rows with an amount the median is about $383,000 and the mean about $28 million. The seven largest settlements are about 62 per cent of the total.
    Source
    OFAC yearly enforcement tables and the notices for the five rows, checked 2026-09-20
    Pages
    /blog/what-283-penalties-look-like/

  3. 20 September 2026, Error corrected

    Trade figures were double-counted in part of the mirror-statistics data

    The page said
    The machinery-exports note said Armenia reported about $55 million of machinery exports to Russia in 2021 and about $1.25 billion in 2022, and that German and US shipments into Kyrgyzstan rose more than tenfold. The Armenia page said inbound shipments rose in step with the onward figure.
    The source says
    The UN Comtrade API returns each aggregate row twice, once with partner2Code 0 and once with 899, at the same value, and the ingest kept both. Some series were therefore doubled. Corrected: Armenia reported about $27.5 million in 2021 and about $643 million in 2022 (the twenty-three-fold rise is unchanged), and inbound shipments to Kyrgyzstan rose about ninefold. Inbound shipments to Armenia rose less than three-fold and then eased, so the earlier 'in step' wording was removed. The ingest now keeps only the partner2Code 0 aggregate.
    Source
    UN Comtrade public preview API, queried 2026-09-20 for Armenia to Russia, HS 84, 2021 (two rows, both 15,310,795.02 USD)
    Pages
    /blog/machinery-exports-after-2022/, /blog/mirror-statistics-method/, /reference/jurisdictions/am/, /reference/jurisdictions/kg/

  4. 19 September 2026, Change to what this site says about itself

    Google Analytics added; the promised alternative was not used

    The page said
    The privacy page said that if analytics were ever added it would be Cloudflare Web Analytics, which is cookieless.
    The source says
    Google Analytics was added instead. The old promise was removed rather than left standing, and the page now says what Google Analytics collects and that visitors from the EU, EEA and UK are not measured.
    Source
    This site's own pages
    Pages
    /privacy/

  5. 15 September 2026, Change to what this site says about itself

    This site now carries advertising

    The page said
    The privacy and about pages said the site carried no advertising and set no cookies.
    The source says
    Those statements were true when written and stopped being true when advertising was planned. The pages were rewritten before any ad code was added, and the sources page records what that means for datasets licensed for non-commercial use.
    Source
    This site's own pages
    Pages
    /privacy/, /about/, /sources/

  6. 7 September 2026, Error corrected

    Standard Chartered (OFAC, 2019) described as a wire-stripping case

    The page said
    The case page treated the settlement as a second payment-message-falsification case.
    The source says
    The OFAC notice describes Iran-related accounts at the bank's Dubai branches, held for general trading companies and operated by customers physically in Iran. It is a third-country account and front-company case. The page and its technique tags were changed.
    Source
    OFAC penalty notice, Standard Chartered Bank, 2019
    Pages
    /cases/standard-chartered-2019/

  7. 7 September 2026, Error corrected

    Binance described as a screening failure alongside Bittrex

    The page said
    Binance was grouped with Bittrex as a sanctions-screening failure.
    The source says
    OFAC's notice finds the trade-matching engine paired US users with sanctioned-jurisdiction users solely by price and time, that senior management knew, and that the compliance programme was deliberately a paper programme. It was found egregious; Bittrex was found non-egregious.
    Source
    OFAC penalty notice, Binance Holdings Ltd, 2023
    Pages
    /cases/binance-2023/, /techniques/crypto-rails/, /blog/what-283-penalties-look-like/

  8. 7 September 2026, Error corrected

    Clearstream described generically as a custody case

    The page said
    The page described a general custody failure.
    The source says
    The notice describes a free-of-payment transfer made after OFAC had raised the business, which changed record ownership while leaving the Central Bank of Iran's beneficial interest intact — in OFAC's words 'buried one layer deeper in the custodial chain'. The page now says that.
    Source
    OFAC penalty notice, Clearstream Banking S.A., 2014
    Pages
    /cases/clearstream-2014/

  9. 7 September 2026, Clarified

    Two different Standard Chartered totals, both correct

    The page said
    The case gave $639,023,750; Treasury's penalties list gives $657,040,033.
    The source says
    Both are right. The second is the global settlement plus a separate $18,016,283 Zimbabwe matter. The page states both, and case penalty figures now reconcile against the ingested OFAC dataset as a build check.
    Source
    OFAC penalties and enforcement information; OFAC penalty notice, 2019
    Pages
    /cases/standard-chartered-2019/

  10. 7 September 2026, Error corrected

    Red-flag indicators attributed to documents that do not contain them

    The page said
    Three indicators were attributed to OFAC's 50 percent guidance; BIS red flags to the 'Don't Let This Happen to You' case compendium; two indicators claimed OFAC's virtual currency guidance mentions mixers; several maritime indicators cited the wrong advisory; several FATF paraphrases had drifted from the published wording.
    The source says
    The library was rebuilt from the sources, 88 to 74 indicators. The 50 percent guidance is a one-page interpretive rule with no indicators. The BIS list is Supplement No. 3 to Part 732 of the EAR. OFAC's virtual currency guidance never mentions mixers (FATF's does). Every indicator now carries a verbatim source quote that the build asserts appears in the extracted source text.
    Source
    OFAC, BIS, FATF and Egmont documents as cited on each indicator
    Pages
    /reference/red-flags/

  11. 7 September 2026, Error corrected

    Nine claims in technique prose the cited sources do not support

    The page said
    Technique pages said the 2020 maritime advisory describes physical cargo blending and unverifiable insurance, that voyage deviations came from the 2019 Syria advisory, that OFAC guidance names mixers, that the advisory names 'poor weather' and 'outside recognised transfer areas' for ship-to-ship transfers, that FATF names layering as the most common method, that a market-value indicator is first in FATF's list, and that FATF has an indicator on inability to evidence movement of goods.
    The source says
    Each was corrected or removed on the page. The 2020 advisory describes falsified documents disguising origin; unverifiable insurance is the 2023 price cap advisory; voyage deviations are in the 2020 advisory; ship-to-ship wording is 'especially at night or in areas determined to be high risk'; FATF identifies shell companies as the most common vehicle. Where a claim is this site's own inference it is now labelled as analysis. Technique prose now carries numbered citations to verified quotes.
    Source
    OFAC 2018, 2019, 2020 and 2023 advisories; FATF and Egmont Group reports
    Pages
    /techniques/cargo-origin-blending/, /techniques/opaque-marine-insurance/, /techniques/ship-to-ship-transfers/, /techniques/mixers-and-chain-hopping/, /techniques/shell-company-layering/, /techniques/trade-misinvoicing/

  12. 7 September 2026, Error corrected

    'Loitering' removed from ship-to-ship page in error, then restored with the right source

    The page said
    An earlier pass removed 'loitering' because OFAC's advisory does not describe it.
    The source says
    It is a UN Panel of Experts finding (S/2018/171, para. 49), and the page now cites it there.
    Source
    UN Panel of Experts on the DPRK, S/2018/171
    Pages
    /techniques/ship-to-ship-transfers/

  13. 2 October 2026, Error corrected

    Syria wrongly listed as a programme on three cases; Sudan and Cuba were missing

    The page said
    The BNP Paribas, Commerzbank and Fokker Services cases were tagged to the Syria programme, and BNP and Commerzbank omitted Sudan and Cuba, although OFAC's releases for those settlements name the Sudanese, Iranian, Cuban and Burmese regulations (BNP, Commerzbank) and the Iranian and Sudanese regulations (Fokker) and none names Syria.
    The source says
    The three cases are tagged to the programmes OFAC's releases name, and a Sudan programme page now exists. Several other cases (Danfoss, Wells Fargo, UniCredit, Bittrex, ShapeShift) were also given a Sudan tag where the release names it.
    Source
    OFAC enforcement information for BNP Paribas (30 June 2014) and Commerzbank (12 March 2015); OFAC enforcement release for Fokker Services (5 June 2014)
    Pages
    /cases/bnp-paribas-2014/, /cases/commerzbank-2015/, /cases/fokker-services-aircraft-parts/, /reference/programs/syria/

  14. 2 October 2026, Error corrected

    Apple Distribution International: designation and Payment A dates corrected

    The page said
    The page said Payment A was released on 30 June, the day JSC New Opportunities was designated, and that Okko was covered from 30 June.
    The source says
    OFSI's notice says the designation was published on 29 June 2022 and that Payment A was processed on that day, with a value date of 30 June. Payment B was instructed on 30 June.
    Source
    OFSI, Imposition of Monetary Penalty: Apple Distribution International Limited, 19 March 2026, paras 10, 13 and 14
    Pages
    /cases/apple-distribution-international-2026/

  15. 2 October 2026, Error corrected

    Rice Lake: date General Licence H was revoked corrected

    The page said
    The page said the general licence under which Dini sold to Iran was revoked on 27 May 2018.
    The source says
    OFAC's release says it was revoked on 27 June 2018, following the 8 May 2018 announcement of the US withdrawal from the JCPOA.
    Source
    OFAC enforcement release, Rice Lake Weighing Systems, 12 August 2026, footnote 2
    Pages
    /cases/rice-lake-weighing-iran-2026/