Sanctions Evasion Reference

Facilitation

Approving, financing, guaranteeing, brokering or otherwise assisting a transaction by a foreign person that the assisting party could not lawfully perform itself.

reviewed

2026-08-20

Facilitation rules stop a restricted party from doing indirectly what it cannot do directly. A US person who arranges, approves or supports a foreign affiliate’s prohibited transaction can violate the prohibition without ever touching the goods or the money.

It is the provision under which head-office staff, group treasurers and in-house counsel are most often caught, because the conduct at issue is approving something rather than doing it.

Where this term is used

  • What is dual-use re-export diversion? — 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.
  • How is correspondent banking used to evade sanctions? — 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 is a professional enabler? — 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.

Related terms

  • 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.
  • Professional enabler — A lawyer, accountant, formation agent, broker or similar professional whose services are essential to concealing ownership or moving restricted value.
  • Wilful blindness — Deliberately avoiding knowledge of a fact that would create liability, treated in enforcement practice as equivalent to knowing it.

Sources

  1. Frequently Asked Questions. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.
  2. Civil Penalties and Enforcement Information. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.

All glossary terms