Sanctions Evasion Reference

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.

step

5 of 7

reviewed

2026-08-20

The single most useful thing to understand about enforcement in this field is that a large case is almost never handled by one authority.

The division of labour

Financial sanctions authorities — OFAC in the United States, OFSI in the United Kingdom, national competent authorities across the EU — impose civil monetary penalties for dealings with restricted parties or property.

Export control authorities — BIS in the United States and its counterparts elsewhere — handle the movement of controlled items, and can deny export privileges entirely, which for a manufacturer is frequently a graver consequence than any fine.

Prosecutors handle criminal conduct: conspiracy, false statements, smuggling, fraud on a bank.

Financial intelligence units receive suspicious activity reports and are frequently where an investigation begins, though their reports are confidential and never appear as sources.

Why the parallel structure matters when reading a figure

The ZTE resolution documented on this site involved a concurrent OFAC settlement, a BIS settlement and a Department of Justice plea agreement. The OFAC component was around a hundred million dollars; the aggregate was several times that.

A penalty figure quoted without saying which authority imposed it is close to meaningless, and this is the most common error in press coverage of these cases.

How the cases are actually built

Overwhelmingly from the institution’s own records. Comparing the instructions a bank received with the messages it sent, or an exporter’s internal correspondence with its shipping documents, is the standard method, and it is why the facts are so rarely contested.

Read next

Terms used on this page

  • Screening — Automated comparison of names, identifiers and other transaction data against sanctions lists and internal watchlists, at onboarding and on each payment.
  • Suspicious activity report — A confidential report filed by a regulated firm with its national financial intelligence unit when it knows or suspects that activity may involve criminal proceeds or sanctioned parties.
  • Financial intelligence unit — The national agency that receives suspicious activity reports, analyses them, and disseminates intelligence to law enforcement and to counterpart units abroad.
  • Facilitation — Approving, financing, guaranteeing, brokering or otherwise assisting a transaction by a foreign person that the assisting party could not lawfully perform itself.
  • Wilful blindness — Deliberately avoiding knowledge of a fact that would create liability, treated in enforcement practice as equivalent to knowing it.

Sources

  1. Civil Penalties and Enforcement Information. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.
  2. Financial sanctions enforcement: decisions and monetary penalties imposed. HM Treasury, Office of Financial Sanctions Implementation, 2026.
  3. Export Enforcement. U.S. Bureau of Industry and Security, 2026.
  4. Office of Public Affairs press releases. U.S. Department of Justice, 2026.
  5. CourtListener and the RECAP Archive. Free Law Project, 2026.