Sanctions Evasion Reference

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.

reviewed

2026-08-20

Attestation is a compliance mechanism used wherever verification at source is impossible: the party closest to the fact certifies it, and everyone downstream relies on the certificate.

It is also a single point of failure. Where the attesting party is the one that benefits from the statement being false, the control depends entirely on the recipient’s willingness to ask for the documents behind it. The distinction between holding an attestation and testing one is the whole subject of the maritime oil advisory.

Where this term is used

  • What is 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.
  • What is 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? — 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.

Related terms

  • 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.
  • 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.
  • Certificate of origin — A document certifying the country in which goods were produced, used to determine tariff treatment and whether origin-based restrictions apply.

Sources

  1. Sanctions Advisory for the Maritime Oil Industry and Related Sectors. U.S. Department of the Treasury, Office of Foreign Assets Control, 2023. Price cap advisory, 12 October 2023.

All glossary terms