# Sanctions Evasion Reference

> A free public reference on the techniques used to evade sanctions and export controls, written from the detection side: what investigators look for, how schemes were uncovered, and what the enforcement record shows.

## Editorial constraint

Every page on this site is written from the detection side. Mechanics are described only at the
level published in official advisories, FATF and Egmont Group typology reports, UN Panel of Experts
reports and court filings. Every technique page ends on red-flag indicators, how the method is
detected, and the documented enforcement record. The site contains no operational instruction and
no vessel-level data; vessel records are kept at https://sanctionedvessels.org.

This is educational reference material, not legal or compliance advice.

## Techniques

### Corporate concealment

- [What is a front company?](https://sanctionsevasion.org/techniques/front-companies/): 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 shell company layering?](https://sanctionsevasion.org/techniques/shell-company-layering/): Layering is the use of successive companies in different jurisdictions between an asset and its owner, so that no single register, filing or payment record shows the connection between them.
- [What are nominee directors and nominee shareholders?](https://sanctionsevasion.org/techniques/nominee-directors/): A nominee is formally recorded as a company's director or shareholder but acts on an undisclosed party's instructions. The register names the nominee; the decisions belong to someone else.
- [What is ownership threshold structuring?](https://sanctionsevasion.org/techniques/ownership-threshold-structuring/): Arranging shareholdings so that designated parties own less than the percentage at which ownership is automatically attributed, while control of the entity stays where it was.

### Trade and customs

- [What is trade misinvoicing?](https://sanctionsevasion.org/techniques/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 HS code misclassification?](https://sanctionsevasion.org/techniques/hs-code-misclassification/): Declaring goods under a Harmonised System commodity code that does not describe them, so that they attract the wrong duty, escape a licence requirement, or disappear from the statistics that would show them.
- [What is a phantom shipment?](https://sanctionsevasion.org/techniques/phantom-shipments/): A phantom shipment is a trade transaction that is documented, financed and paid in full when no goods, or far fewer goods, were ever shipped. The payment is the entire purpose.
- [What is third-country transshipment?](https://sanctionsevasion.org/techniques/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.
- [What is dual-use re-export diversion?](https://sanctionsevasion.org/techniques/dual-use-re-export/): Buying controlled civil-use goods lawfully in an open market and re-exporting them to a restricted end user, exploiting the fact that the item itself looks entirely ordinary.
- [What is end-user certificate fraud?](https://sanctionsevasion.org/techniques/end-user-certificate-fraud/): Supplying a false statement of who will use controlled goods and for what, so that a licence is granted or a sale proceeds on a representation the exporter cannot verify.

### Maritime

- [What is cargo origin blending?](https://sanctionsevasion.org/techniques/cargo-origin-blending/): Mixing, decanting or re-documenting a commodity in transit so that restricted cargo is no longer traceable to its origin and arrives certified as coming from somewhere else.
- [What is a ship-to-ship transfer?](https://sanctionsevasion.org/techniques/ship-to-ship-transfers/): 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 AIS manipulation and AIS spoofing?](https://sanctionsevasion.org/techniques/ais-manipulation/): Disabling a ship's position transponder, or transmitting false position data through it, so that the vessel's recorded track does not show where it actually went.
- [What is flag hopping?](https://sanctionsevasion.org/techniques/flag-hopping/): Re-registering a ship repeatedly between flag states, often to registries with limited oversight, so that its regulatory history is broken and its documented identity keeps changing.
- [What is opaque marine insurance?](https://sanctionsevasion.org/techniques/opaque-marine-insurance/): Presenting protection and indemnity or hull cover from a provider that cannot be identified, or whose ability to meet a claim cannot be established, in order to satisfy a requirement to be insured.
- [What is price cap attestation fraud?](https://sanctionsevasion.org/techniques/price-cap-attestation-fraud/): Providing a false or unsupported statement that oil was bought at or below a capped price, so that shipping, insurance and financing services remain available for a cargo that does not qualify.

### Banking and payments

- [How is correspondent banking used to evade sanctions?](https://sanctionsevasion.org/techniques/correspondent-banking-abuse/): 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.
- [What are third-country bank accounts and how are they used?](https://sanctionsevasion.org/techniques/third-country-bank-accounts/): Holding accounts in a jurisdiction unconnected to the restricted party, the goods or the contract, so that payments reach and leave the restricted economy without ever appearing to touch it.
- [What is hawala and how does informal value transfer work?](https://sanctionsevasion.org/techniques/hawala-and-informal-value-transfer/): Settling obligations between brokers in different countries by netting them against each other, so a customer's payment reaches a recipient abroad without any funds crossing a border.
- [How are gold and commodities used to settle sanctioned trade?](https://sanctionsevasion.org/techniques/gold-and-commodity-barter/): Settling cross-border obligations by moving physical gold or fungible commodities instead of currency, so that value transfers without any payment entering the banking system.

### Digital assets

- [How is cryptocurrency used to evade sanctions?](https://sanctionsevasion.org/techniques/crypto-rails/): 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 stablecoin settlement and why does it matter for sanctions?](https://sanctionsevasion.org/techniques/stablecoin-settlement/): Settling commercial obligations in a fiat-referenced token, so that a dollar-denominated trade can be paid without a dollar ever passing through a correspondent bank.
- [What are mixers and chain hopping?](https://sanctionsevasion.org/techniques/mixers-and-chain-hopping/): Breaking the traceability of on-chain funds by pooling them with other users' funds, or by moving them between blockchains, so that outputs cannot be readily linked to their inputs.

### Aviation

- [How are aircraft parts procured in breach of sanctions?](https://sanctionsevasion.org/techniques/aviation-parts-procurement/): Buying airframe and engine components through intermediaries in unrestricted countries, so that parts for a restricted operator's Western-built fleet arrive with clean paperwork and no airworthiness trail.

### Professional enablers

- [What is a professional enabler?](https://sanctionsevasion.org/techniques/professional-enablers/): A lawyer, accountant, formation agent or broker whose services are what makes a concealment structure work, and whose repeated involvement across unconnected clients is itself the evidence.

## Learn

- [What are sanctions and how do they actually work?](https://sanctionsevasion.org/learn/what-are-sanctions/): 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?](https://sanctionsevasion.org/learn/how-designations-work/): 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?](https://sanctionsevasion.org/learn/the-50-percent-rule/): 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?](https://sanctionsevasion.org/learn/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?](https://sanctionsevasion.org/learn/who-enforces-sanctions/): 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?](https://sanctionsevasion.org/learn/how-evasion-is-detected/): 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?](https://sanctionsevasion.org/learn/sanctions-vs-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.

## Enforcement cases

- [Adani Enterprises: 35 cargoes of LPG that were not Omani](https://sanctionsevasion.org/cases/adani-enterprises-lpg/): Adani Enterprises settled at $275,000,000 in 2026 after buying LPG from a Dubai trader that was in fact Iranian. The vessels carrying it were spoofing and going dark throughout.
- [Citibank London: 970 payments, one missed prefix](https://sanctionsevasion.org/cases/cbna-london-2026/): Citibank's London branch processed 970 payments worth £19.7m in breach of Russia sanctions in 2026, including £4.3m within 24 hours of a designation, after screening missed a Russian corporate prefix and a 50 per cent ownership test.
- [Insurance against a risk the seller creates](https://sanctionsevasion.org/cases/hormuz-marine-insurance/): Treasury designated two Iranian maritime insurance entities in 2026 for compelling vessels transiting the Strait of Hormuz to buy IRGC-approved policies, accepting payment in digital assets.
- [Family International Realty: transferred to relatives](https://sanctionsevasion.org/cases/family-international-realty/): A Miami realtor and its owner paid $1,076,923 in 2025 after moving nominal ownership of two sanctioned oligarchs' condominiums to their non-designated family members and to shell companies those relatives owned.
- [Flighttime: a false end-user certificate](https://sanctionsevasion.org/cases/flighttime-enterprises-aviation/): An Ohio aircraft parts supplier and three employees were charged in 2025 over shipments to Russian end users, using mislabelled shipments, false certifications and intermediary countries.
- [GVA Capital: managed through a nephew](https://sanctionsevasion.org/cases/gva-capital-kerimov/): A San Francisco venture firm was penalised $215,988,868 in 2025 for continuing to manage an investment for Suleiman Kerimov after his designation, working through a nephew it knew was his proxy.
- [Herbert Smith Freehills Moscow: six payments while closing the office](https://sanctionsevasion.org/cases/hsf-moscow-2024/): A law firm's Moscow office paid six designated Russian banks £3,932,392.10 while closing its office after the 2022 invasion, then received a 50 per cent penalty reduction for its own group's disclosure to OFSI.
- [TGR Group: cash in one city, USDT in another](https://sanctionsevasion.org/cases/tgr-group-usdt/): Treasury designated a network in 2024 that moved value for Russian elites by pairing bulk cash handovers against transfers of dollar-referenced stablecoins, settling the two against each other.
- [Binance: a matching engine with no jurisdiction in it](https://sanctionsevasion.org/cases/binance-2023/): Binance settled 1,667,153 apparent violations in 2023. Its matching engine paired US users with users in sanctioned jurisdictions, and OFAC found senior management knew, and undermined its own controls.
- [British American Tobacco and the North Korea joint venture](https://sanctionsevasion.org/cases/british-american-tobacco-dprk/): BAT paid $508,612,492 in 2023 over a scheme in which tobacco was exported to North Korea and paid for through the US financial system using a network of intermediary companies.
- [Blender, Tornado Cash and Sinbad: designating the mixers](https://sanctionsevasion.org/cases/mixer-designations/): Between 2022 and 2023 Treasury designated three virtual currency mixers used to launder proceeds of North Korean state-sponsored theft, turning a tracing problem into a list-matching one.
- [Lumber Marine and Ice Pearl: the first price cap designations](https://sanctionsevasion.org/cases/price-cap-first-designations/): Treasury designated two shipowners in October 2023 for carrying Russian crude bought above the cap while using US service providers, the first enforcement action under the price cap regime.
- [Swedbank Latvia: a client banking from Crimea](https://sanctionsevasion.org/cases/swedbank-latvia-crimea/): Swedbank Latvia paid $3,430,900 in 2023 for 386 apparent violations, after a shipping client sent payments through its e-banking platform from an IP address in Crimea via US correspondent banks.
- [Bittrex: onboarding data collected and not screened](https://sanctionsevasion.org/cases/bittrex-2022/): Bittrex paid OFAC $24,280,829.20 in 2022 for 116,421 apparent violations, having collected customer IP and address data at onboarding without screening it for sanctioned jurisdictions.
- [Sojitz Hong Kong: dollar payments for Iranian-origin polyethylene](https://sanctionsevasion.org/cases/sojitz-hong-kong-iran-hdpe/): A Hong Kong trading company paid $5,228,298 in 2022 after making US dollar payments through US banks for approximately 64,000 tons of Iranian-origin polyethylene bought from a supplier in Thailand.
- [Toll Holdings: a freight forwarder's 2,958 payments](https://sanctionsevasion.org/cases/toll-holdings-freight-forwarding/): An Australian logistics company paid $6,131,855 in 2022 over 2,958 payments through the US financial system connected to shipments to, from or through North Korea, Iran and Syria.
- [Nordgas: re-exporting US pressure switches to Iran](https://sanctionsevasion.org/cases/nordgas-iran-reexport/): An Italian boiler component maker paid $950,000 in 2021 after re-exporting 27 shipments of US-origin air pressure switches to Iranian customers, having been told expressly that Iranian end users were prohibited.
- [Essentra FZE: cigarette filters to North Korea through front companies](https://sanctionsevasion.org/cases/essentra-fze-dprk/): A UAE manufacturer paid $665,112 in 2020 after exporting cigarette filters to North Korea through front companies in China and elsewhere, having been asked in writing not to name the real destination.
- [Halkbank, Zarrab and Atilla: oil revenue disguised as food](https://sanctionsevasion.org/cases/halkbank-zarrab-atilla/): A Turkish banker was convicted in 2018 of using a state-owned bank to release Iranian oil revenue through gold and currency, with false documents making the transactions appear to involve food.
- [MID-SHIP Group: payments connected to blocked vessels](https://sanctionsevasion.org/cases/mid-ship-group-irisl/): A New York shipping agency paid $871,837 in 2019 over five funds transfers totalling about $472,861 that related to vessels identified on the SDN List after their operator was designated.
- [Standard Chartered: 9,335 payments from accounts in Dubai](https://sanctionsevasion.org/cases/standard-chartered-2019/): Standard Chartered settled with OFAC for $657,040,033 across two matters in 2019. The larger concerned Iran-related accounts at its Dubai branches, used by customers physically located in Iran.
- [Epsilon Electronics: selling to a distributor that sold to Iran](https://sanctionsevasion.org/cases/epsilon-electronics-iran/): A California car audio maker settled at $1,500,000 in 2018 after litigation, over 39 invoices to a UAE distributor it knew or had reason to know sent most or all of its products to Iran.
- [ZTE: front companies and an internal plan to keep supplying Iran](https://sanctionsevasion.org/cases/zte-2017/): ZTE paid OFAC $100,871,266 in 2017 for 251 apparent violations, concurrently with settlements with the Bureau of Industry and Security and a plea agreement with the Department of Justice.
- [Commerzbank: a manual payment queue for Iranian counterparties](https://sanctionsevasion.org/cases/commerzbank-2015/): Commerzbank settled 1,596 apparent violations in 2015. Employees deleted references to Iranian banks, substituted Commerzbank's own name as originator, and built a manual queue to keep those payments out of automated processing.
- [Clearstream: one layer deeper in the custody chain](https://sanctionsevasion.org/cases/clearstream-2014/): Clearstream settled at $151,902,000 in 2014. After OFAC raised its Iranian business, it moved securities entitlements so that the record owner changed and the Central Bank of Iran's beneficial interest did not.
- [BNP Paribas: the $963m correspondent banking settlement](https://sanctionsevasion.org/cases/bnp-paribas-2014/): BNP Paribas settled 3,897 apparent violations in 2014 over a systematic practice, across multiple branches and business lines, of removing sanctioned parties from dollar payment messages sent to US banks.
- [Fokker Services: 1,153 shipments of aircraft parts to Iran and Sudan](https://sanctionsevasion.org/cases/fokker-services-aircraft-parts/): A Dutch aerospace services company settled potential liability of $50,922,208 in 2014 after five years of routing US-origin aircraft spare parts to Iranian and Sudanese customers.

## Reference

- [Red-flag indicator library](https://sanctionsevasion.org/reference/red-flags/): Every indicator on this site, attributed to its source advisory, filterable by technique, category, authority and year.
- [Designations feed](https://sanctionsevasion.org/reference/designations/): Rolling record of OFAC actions, rebuilt daily.

### Authorities

- [BIS: the Bureau of Industry and Security](https://sanctionsevasion.org/reference/authorities/bis/): The US Commerce Department bureau that administers export controls on dual-use items, maintains the Entity List, and enforces the Export Administration Regulations.
- [DFAT: the Australian Department of Foreign Affairs and Trade](https://sanctionsevasion.org/reference/authorities/dfat/): The Australian department administering autonomous and UN sanctions, maintaining the Consolidated List and issuing permits.
- [Global Affairs Canada](https://sanctionsevasion.org/reference/authorities/gac/): The Canadian department responsible for sanctions under the Special Economic Measures Act and related statutes, publishing consolidated lists and administering permits.
- [OFAC: the Office of Foreign Assets Control](https://sanctionsevasion.org/reference/authorities/ofac/): The US Treasury office that administers and enforces most US economic sanctions, publishes the SDN List, issues licences and imposes civil monetary penalties.
- [EU sanctions: the Council, the Commission and member state authorities](https://sanctionsevasion.org/reference/authorities/eu/): The EU adopts sanctions by Council decision and regulation; national competent authorities in each member state implement, licence and enforce them.
- [SECO: the Swiss State Secretariat for Economic Affairs](https://sanctionsevasion.org/reference/authorities/seco/): The Swiss authority implementing sanctions under the Embargo Act, maintaining the searchable sanctions list and administering exemptions.
- [UN sanctions: the Security Council and its committees](https://sanctionsevasion.org/reference/authorities/un/): The Security Council imposes sanctions by resolution; sanctions committees maintain the lists and Panels of Experts monitor and report on implementation.
- [OFSI: the Office of Financial Sanctions Implementation](https://sanctionsevasion.org/reference/authorities/ofsi/): The UK Treasury office that implements financial sanctions, maintains the UK consolidated list, issues licences and imposes monetary penalties.

### Programmes

- [North Korea sanctions](https://sanctionsevasion.org/reference/programs/dprk/): The most comprehensive UN-mandated regime, prohibiting most trade with North Korea, backed by Panel of Experts reporting that documents evasion in unusual detail.
- [Russia sanctions](https://sanctionsevasion.org/reference/programs/russia/): Measures imposed from 2014 and greatly expanded from 2022, combining designations, sectoral restrictions, export controls and a price cap on seaborne oil.
- [Syria sanctions](https://sanctionsevasion.org/reference/programs/syria/): US, EU and UK measures restricting dealings with the Syrian government, its energy sector and designated parties, with substantial humanitarian carve-outs.
- [Iran sanctions](https://sanctionsevasion.org/reference/programs/iran/): A layered set of US, EU and UN measures dating from 1979 and substantially rebuilt after 2018, covering energy, finance, shipping, and proliferation-related procurement.
- [Belarus sanctions](https://sanctionsevasion.org/reference/programs/belarus/): Measures imposed after 2020 and expanded from 2022, largely mirroring the Russia programme in scope and, deliberately, in the gaps it is meant to close.
- [Venezuela sanctions](https://sanctionsevasion.org/reference/programs/venezuela/): US measures targeting the Venezuelan government, the state oil company and designated individuals, with restrictions on debt, equity and petroleum dealings.

### Jurisdictions

- [Armenia](https://sanctionsevasion.org/reference/jurisdictions/am/): A small economy in the Eurasian Economic Union whose reported machinery exports to Russia rose roughly twenty-three-fold in the year direct routes closed, the largest single change this site's mirror-statistics analysis has found.
- [Georgia](https://sanctionsevasion.org/reference/jurisdictions/ge/): A transit economy on the Black Sea whose trade and re-export figures feature in the same commodity-code analysis applied to other neighbouring states.
- [Cyprus](https://sanctionsevasion.org/reference/jurisdictions/cy/): An EU member state with a substantial corporate services and holding-company sector that appears in a large share of published beneficial ownership concealment material.
- [Kyrgyzstan](https://sanctionsevasion.org/reference/jurisdictions/kg/): A Eurasian Economic Union member whose onward machinery exports to Russia rose roughly thirtyfold between 2021 and 2023, alongside a more-than-tenfold rise in German and US shipments into the country over the same period.
- [Kazakhstan](https://sanctionsevasion.org/reference/jurisdictions/kz/): A customs union member with extensive land connections to Russia and China, prominent in trade-statistics analysis of re-routed goods since 2022.
- [Panama](https://sanctionsevasion.org/reference/jurisdictions/pa/): One of the largest ship registries in the world, which places it in maritime analysis by volume rather than by any distinguishing feature of its rules.
- [United Arab Emirates](https://sanctionsevasion.org/reference/jurisdictions/ae/): A major re-export hub and financial centre that appears in enforcement records across almost every technique on this site, principally because of the volume of trade that passes through it.
- [Hong Kong](https://sanctionsevasion.org/reference/jurisdictions/hk/): A major financial and trading centre whose company formation regime, banking sector and re-export role place it in a large share of published corporate concealment cases.
- [Türkiye](https://sanctionsevasion.org/reference/jurisdictions/tr/): A large manufacturing and transit economy whose trade with several restricted destinations has grown substantially, making it central to third-country routing analysis.
- [Singapore](https://sanctionsevasion.org/reference/jurisdictions/sg/): A major trade financing, commodity trading and shipping centre whose intermediaries appear in enforcement records for the same volume reasons as other large hubs.

### Lists

- [The Consolidated Screening List](https://sanctionsevasion.org/reference/lists/consolidated-screening-list/): A single US government endpoint bundling the OFAC, Commerce and State export screening lists, published by the International Trade Administration with an API and a search interface.
- [The UK consolidated list](https://sanctionsevasion.org/reference/lists/uk-sanctions-list/): The UK Treasury's consolidated list of financial sanctions targets, published by OFSI in machine-readable formats alongside the separate UK Sanctions List maintained by the Foreign Office.
- [The BIS Entity List](https://sanctionsevasion.org/reference/lists/entity-list/): A US export control list of parties subject to specific licence requirements, published as Supplement No. 4 to Part 744 of the Export Administration Regulations.
- [The UN Security Council Consolidated List](https://sanctionsevasion.org/reference/lists/un-consolidated-list/): The list of individuals and entities subject to measures imposed by the Security Council, maintained by its sanctions committees and implemented through national law.
- [The EU consolidated list](https://sanctionsevasion.org/reference/lists/eu-consolidated-list/): The consolidated list of persons, groups and entities subject to EU financial sanctions, published centrally and implemented by national competent authorities in each member state.
- [The SDN List](https://sanctionsevasion.org/reference/lists/sdn-list/): The Specially Designated Nationals and Blocked Persons List: the primary US sanctions list, published by OFAC in several machine-readable formats and updated as designations are made.

## Notes

- [What the published OFAC penalty record actually looks like](https://sanctionsevasion.org/blog/what-283-penalties-look-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](https://sanctionsevasion.org/blog/machinery-exports-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](https://sanctionsevasion.org/blog/mirror-statistics-method/): 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.

## About

- [About](https://sanctionsevasion.org/about/): What this site is, who it is for, the editorial approach, and how corrections are handled.
- [Sources](https://sanctionsevasion.org/sources/): Every dataset used, with publisher, licence, update cadence and last fetch date, generated from ingest metadata.
- [Terms](https://sanctionsevasion.org/terms/): Terms of use.
- [Privacy](https://sanctionsevasion.org/privacy/): What is and is not collected.
- [Contact](https://sanctionsevasion.org/contact/): Corrections and contact.

## Glossary (79 terms)

- **Asset freeze** (https://sanctionsevasion.org/reference/glossary/asset-freeze/): The prohibition on dealing with funds or economic resources owned, held or controlled by a designated person, and on making funds available to them.
- **Attestation** (https://sanctionsevasion.org/reference/glossary/attestation/): A signed statement by a party in a transaction confirming a fact that the recipient cannot itself observe, relied on as the basis for providing a service.
- **Automatic Identification System** (https://sanctionsevasion.org/reference/glossary/ais/): A mandatory maritime transponder system that broadcasts a vessel's identity, position, course and speed to nearby vessels and shore stations.
- **Beneficial owner** (https://sanctionsevasion.org/reference/glossary/beneficial-owner/): The natural person who ultimately owns or controls an entity, or on whose behalf a transaction is conducted, regardless of whose name appears on the register.
- **Bill of lading** (https://sanctionsevasion.org/reference/glossary/bill-of-lading/): A document issued by a carrier acknowledging receipt of cargo, stating its terms of carriage, and in negotiable form serving as a document of title to the goods.
- **Blockchain analytics** (https://sanctionsevasion.org/reference/glossary/blockchain-analytics/): The practice of clustering addresses and attributing them to real-world services or actors, using on-chain patterns and off-chain information.
- **Blocked property** (https://sanctionsevasion.org/reference/glossary/blocked-property/): Property in which a designated person has an interest, which has come within the jurisdiction and must be frozen, reported and held in a blocked account.
- **Blocking** (https://sanctionsevasion.org/reference/glossary/blocking/): Freezing property and interests in property of a designated person that come within a jurisdiction, so it cannot be transferred, paid, withdrawn or otherwise dealt in.
- **Certificate of origin** (https://sanctionsevasion.org/reference/glossary/certificate-of-origin/): A document certifying the country in which goods were produced, used to determine tariff treatment and whether origin-based restrictions apply.
- **Chain hopping** (https://sanctionsevasion.org/reference/glossary/chain-hopping/): Moving value rapidly between different blockchains, usually through bridges or swap services, to interrupt tracing that works within a single chain.
- **Common High Priority List** (https://sanctionsevasion.org/reference/glossary/common-high-priority-list/): A list of Harmonised System codes covering items assessed as most critical to a restricted military programme, published jointly by export control authorities.
- **Corporate services provider** (https://sanctionsevasion.org/reference/glossary/corporate-services-provider/): A firm that incorporates and administers companies for clients, supplying registered offices, directors, shareholders and company secretarial services.
- **Correspondent banking** (https://sanctionsevasion.org/reference/glossary/correspondent-banking/): An arrangement in which one bank holds an account for another and provides payment and other services on its behalf, usually to give it access to a foreign currency.
- **Customer due diligence** (https://sanctionsevasion.org/reference/glossary/customer-due-diligence/): The ongoing process of understanding a customer's identity, ownership, expected activity and risk, and checking that actual activity remains consistent with it.
- **De minimis rule** (https://sanctionsevasion.org/reference/glossary/de-minimis-rule/): The principle that a foreign-made item becomes subject to US export controls when more than a threshold percentage of its value is US-origin controlled content.
- **Deemed export** (https://sanctionsevasion.org/reference/glossary/deemed-export/): The release of controlled technology or source code to a foreign national inside the exporting country, treated in law as an export to that person's home country.
- **Designation** (https://sanctionsevasion.org/reference/glossary/designation/): The formal act of adding a person, entity, vessel or aircraft to a sanctions list, which triggers the restrictions attached to that programme.
- **Designations feed** (https://sanctionsevasion.org/reference/glossary/designations-feed/): A rolling, machine-readable record of additions to and removals from sanctions lists, published by the issuing authority and republished by aggregators.
- **Dual-use goods** (https://sanctionsevasion.org/reference/glossary/dual-use-goods/): Items with legitimate civil applications that can also contribute to military or weapons programmes, and which are therefore export-controlled.
- **End-user certificate** (https://sanctionsevasion.org/reference/glossary/end-user-certificate/): A document in which the stated recipient of a controlled item certifies who will use it, where, and for what purpose, relied on by exporters and licensing authorities.
- **Enhanced due diligence** (https://sanctionsevasion.org/reference/glossary/enhanced-due-diligence/): Additional scrutiny applied where risk is assessed as higher, including deeper enquiry into source of funds, ownership and the purpose of specific transactions.
- **Entity List** (https://sanctionsevasion.org/reference/glossary/entity-list/): A US Bureau of Industry and Security list of parties subject to specific export licence requirements because of activity contrary to national security or foreign policy interests.
- **Export control** (https://sanctionsevasion.org/reference/glossary/export-control/): A licensing regime that restricts the export, re-export or transfer of specified goods, software and technology by reference to the item, the destination and the end use.
- **Facilitation** (https://sanctionsevasion.org/reference/glossary/facilitation/): Approving, financing, guaranteeing, brokering or otherwise assisting a transaction by a foreign person that the assisting party could not lawfully perform itself.
- **Financial intelligence unit** (https://sanctionsevasion.org/reference/glossary/financial-intelligence-unit/): The national agency that receives suspicious activity reports, analyses them, and disseminates intelligence to law enforcement and to counterpart units abroad.
- **Flag of convenience** (https://sanctionsevasion.org/reference/glossary/flag-of-convenience/): Registration of a ship in a state with which its owners have no genuine connection, chosen for cost, tax or regulatory reasons.
- **Flag state** (https://sanctionsevasion.org/reference/glossary/flag-state/): The country in which a ship is registered, whose law governs the vessel and which is responsible for inspecting and certifying it.
- **Foreign direct product rule** (https://sanctionsevasion.org/reference/glossary/foreign-direct-product-rule/): A rule making a foreign-made item subject to US export controls because it is the direct product of US-origin technology, software or production equipment.
- **Free trade zone** (https://sanctionsevasion.org/reference/glossary/free-trade-zone/): A designated area where goods may be landed, stored, handled and re-exported without the customs formalities that would apply in the domestic territory.
- **Freight forwarder** (https://sanctionsevasion.org/reference/glossary/freight-forwarder/): An intermediary that arranges carriage on behalf of shippers, books space, prepares documentation and may consolidate cargo from several customers.
- **Front company** (https://sanctionsevasion.org/reference/glossary/front-company/): A company that carries on some real business but exists substantially to conceal the involvement of another party in its transactions.
- **Fuzzy matching** (https://sanctionsevasion.org/reference/glossary/fuzzy-matching/): Name-matching that tolerates spelling, transliteration and word-order variation, scoring similarity rather than requiring an exact match.
- **General licence** (https://sanctionsevasion.org/reference/glossary/general-licence/): A published authorisation permitting a defined category of otherwise prohibited transactions, available to anyone who meets its terms without applying.
- **Hawala** (https://sanctionsevasion.org/reference/glossary/hawala/): A value transfer arrangement in which brokers in different countries pay out to each other's customers and settle the resulting obligations between themselves later.
- **HS code** (https://sanctionsevasion.org/reference/glossary/hs-code/): A six-digit commodity code from the World Customs Organization Harmonised System, extended nationally, that determines the tariff and the controls applied to goods.
- **IMO number** (https://sanctionsevasion.org/reference/glossary/imo-number/): A seven-digit identifier assigned to a ship's hull for life by the International Maritime Organization, which does not change with name, owner or flag.
- **Incoterms** (https://sanctionsevasion.org/reference/glossary/incoterms/): Standard trade terms published by the International Chamber of Commerce that allocate cost, risk and responsibility for delivery between buyer and seller.
- **Informal value transfer system** (https://sanctionsevasion.org/reference/glossary/informal-value-transfer-system/): Any arrangement that transfers value between parties without moving funds through the regulated banking system, settling obligations by netting or in kind.
- **Know your customer** (https://sanctionsevasion.org/reference/glossary/know-your-customer/): The obligation on a regulated firm to identify its customer, verify that identity, and understand the purpose of the relationship before providing services.
- **Layering** (https://sanctionsevasion.org/reference/glossary/layering/): Inserting successive intermediate parties, transactions or jurisdictions between an asset and its owner so that the connection cannot be established from any single record.
- **Letter of credit** (https://sanctionsevasion.org/reference/glossary/letter-of-credit/): A bank undertaking to pay a seller against presentation of specified documents, substituting the bank's credit for the buyer's.
- **Mirror statistics** (https://sanctionsevasion.org/reference/glossary/mirror-statistics/): Comparing what one country reports exporting to a partner with what the partner reports importing from it, treating persistent gaps as evidence of misreporting.
- **Mixer** (https://sanctionsevasion.org/reference/glossary/mixer/): A service that pools virtual currency from many users and redistributes it, so that outputs cannot be readily linked to the inputs that funded them.
- **Nested account** (https://sanctionsevasion.org/reference/glossary/nested-account/): The use of a bank's correspondent account by that bank's own respondent institutions, giving unnamed third banks indirect access to the correspondent.
- **Nominee director** (https://sanctionsevasion.org/reference/glossary/nominee-director/): A person who is formally appointed to a company board but who acts on the instructions of an undisclosed party rather than exercising independent judgement.
- **Open registry** (https://sanctionsevasion.org/reference/glossary/open-registry/): A ship registry that accepts vessels owned by foreign nationals without requiring a national ownership or crewing link.
- **Over-invoicing** (https://sanctionsevasion.org/reference/glossary/over-invoicing/): Stating a price above the true value of goods on an invoice, so that the importer transfers more value to the exporter than the trade justifies.
- **Panel of Experts** (https://sanctionsevasion.org/reference/glossary/panel-of-experts/): A group of specialists appointed by the UN Security Council to monitor a sanctions regime and report publicly on violations and evasion methods.
- **Phantom shipment** (https://sanctionsevasion.org/reference/glossary/phantom-shipment/): A trade transaction documented and paid for in full where no goods, or substantially fewer goods, were ever shipped.
- **Price cap** (https://sanctionsevasion.org/reference/glossary/price-cap/): A measure permitting specified services for seaborne oil only where the cargo was bought at or below a stated price, enforced through the service providers rather than at the border.
- **Professional enabler** (https://sanctionsevasion.org/reference/glossary/professional-enabler/): A lawyer, accountant, formation agent, broker or similar professional whose services are essential to concealing ownership or moving restricted value.
- **Proliferation financing** (https://sanctionsevasion.org/reference/glossary/proliferation-financing/): The provision of funds or financial services used for the manufacture, acquisition or transfer of weapons of mass destruction or their delivery systems, contrary to international obligations.
- **Protection and indemnity club** (https://sanctionsevasion.org/reference/glossary/protection-and-indemnity-club/): A mutual association of shipowners that provides third-party liability cover, including for pollution, which ports and states generally require before a vessel may trade.
- **Re-export** (https://sanctionsevasion.org/reference/glossary/re-export/): The onward shipment of a controlled item from the country that first received it to a third country, which may itself require a licence from the original exporting state.
- **Red-flag indicator** (https://sanctionsevasion.org/reference/glossary/red-flag-indicator/): A published, attributable observation that a transaction or relationship warrants further enquiry, drawn from patterns seen in past cases.
- **Respondent bank** (https://sanctionsevasion.org/reference/glossary/respondent-bank/): The bank that holds an account with a correspondent and relies on it to make payments or provide services in a currency or market it cannot reach directly.
- **Sanctions** (https://sanctionsevasion.org/reference/glossary/sanctions/): Restrictions imposed by a state or international body on dealings with a named person, entity, sector or country, enforced against anyone within that authority's jurisdiction.
- **Screening** (https://sanctionsevasion.org/reference/glossary/screening/): Automated comparison of names, identifiers and other transaction data against sanctions lists and internal watchlists, at onboarding and on each payment.
- **Secondary sanctions** (https://sanctionsevasion.org/reference/glossary/secondary-sanctions/): Measures that threaten non-US persons with loss of access to the US market or financial system if they engage in specified dealings with sanctioned parties.
- **Secrecy jurisdiction** (https://sanctionsevasion.org/reference/glossary/secrecy-jurisdiction/): A jurisdiction whose company, banking or trust law limits the information available about ownership and control to foreign authorities and counterparties.
- **Sectoral sanctions** (https://sanctionsevasion.org/reference/glossary/sectoral-sanctions/): Restrictions on particular types of dealing with named entities in a defined economic sector, rather than a full block on all dealings with them.
- **Shadow fleet** (https://sanctionsevasion.org/reference/glossary/shadow-fleet/): A loosely defined group of ageing tankers with opaque ownership and insurance that carry sanctioned or price-capped cargo outside mainstream shipping arrangements.
- **Shell company** (https://sanctionsevasion.org/reference/glossary/shell-company/): A registered company with no significant operations, assets or employees, used to hold assets or to sit in a chain of ownership.
- **Ship-to-ship transfer** (https://sanctionsevasion.org/reference/glossary/ship-to-ship-transfer/): Transferring cargo directly between two vessels at sea or at anchorage rather than through a port terminal.
- **Specially Designated Nationals and Blocked Persons List** (https://sanctionsevasion.org/reference/glossary/sdn-list/): The principal United States sanctions list. Property of anyone on it is blocked and US persons are generally prohibited from dealing with them.
- **Specific licence** (https://sanctionsevasion.org/reference/glossary/specific-licence/): A written authorisation issued to a named applicant permitting a particular transaction that would otherwise be prohibited.
- **Stablecoin** (https://sanctionsevasion.org/reference/glossary/stablecoin/): A virtual asset designed to hold a steady value against a reference such as a national currency, usually by holding reserves or by algorithmic mechanism.
- **Suspicious activity report** (https://sanctionsevasion.org/reference/glossary/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.
- **SWIFT** (https://sanctionsevasion.org/reference/glossary/swift/): A member-owned cooperative operating the messaging network banks use to exchange standardised payment and securities instructions internationally.
- **The 50 percent rule** (https://sanctionsevasion.org/reference/glossary/fifty-percent-rule/): OFAC guidance that any entity owned fifty per cent or more, directly or indirectly, by one or more blocked persons is itself blocked, whether or not it is named.
- **Trade misinvoicing** (https://sanctionsevasion.org/reference/glossary/trade-misinvoicing/): Deliberately misstating the price, quantity or description of goods on trade documents so that the value recorded differs from the value actually exchanged.
- **Trade-based money laundering** (https://sanctionsevasion.org/reference/glossary/trade-based-money-laundering/): Moving value by misrepresenting the price, quantity or quality of goods in international trade, so that the transfer appears as ordinary commerce.
- **Transshipment** (https://sanctionsevasion.org/reference/glossary/transshipment/): Unloading goods from one conveyance and reloading them onto another en route, so that the shipment reaches its destination through an intermediate country.
- **Typology** (https://sanctionsevasion.org/reference/glossary/typology/): A published study describing how a category of illicit activity is actually carried out, built from case material contributed by member jurisdictions.
- **Under-invoicing** (https://sanctionsevasion.org/reference/glossary/under-invoicing/): Stating a price below the true value of goods, so that value is retained abroad or duty and export restrictions are reduced.
- **Virtual asset service provider** (https://sanctionsevasion.org/reference/glossary/virtual-asset-service-provider/): A business that exchanges, transfers, safekeeps or administers virtual assets for others, and which FATF expects to be licensed and supervised like other financial institutions.
- **Wilful blindness** (https://sanctionsevasion.org/reference/glossary/wilful-blindness/): Deliberately avoiding knowledge of a fact that would create liability, treated in enforcement practice as equivalent to knowing it.
- **Wire stripping** (https://sanctionsevasion.org/reference/glossary/wire-stripping/): Removing or altering originator, beneficiary or reference information from a payment message so that screening at an intermediary bank does not identify a restricted party.
- **Zombie registry** (https://sanctionsevasion.org/reference/glossary/zombie-registry/): A ship registry that continues to issue documentation in a state's name after that state has withdrawn authorisation, or that never had it.

## Machine-readable

- [llms-full.txt](https://sanctionsevasion.org/llms-full.txt): This map plus the full text of every glossary definition.
- [glossary.json](https://sanctionsevasion.org/glossary.json): The canonical shared glossary, consumed by the sister sites.
- [designations.json](https://sanctionsevasion.org/api/designations.json): The designations feed as JSON.
- [red-flags.json](https://sanctionsevasion.org/api/red-flags.json): The red-flag indicator library as JSON.
- [sitemap](https://sanctionsevasion.org/sitemap-index.xml): Sitemap index, split by collection.