Sanctions Evasion Reference

Freight forwarder

An intermediary that arranges carriage on behalf of shippers, books space, prepares documentation and may consolidate cargo from several customers.

reviewed

2026-08-20

Forwarders sit between the exporter and the physical movement of goods, and they prepare much of the documentation the rest of the system relies on. A forwarder that routinely amends documents after issue at a customer’s request, or that accepts delivery addresses in place of a declared end user, is doing something the export control system depends on it not doing.

BIS enforcement material treats delivery to a forwarder rather than to the stated end user as a standing red flag for exactly this reason.

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 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.
  • What is a phantom shipment? — 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? — 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.

Related terms

  • 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.
  • Incoterms — Standard trade terms published by the International Chamber of Commerce that allocate cost, risk and responsibility for delivery between buyer and seller.
  • Professional enabler — A lawyer, accountant, formation agent, broker or similar professional whose services are essential to concealing ownership or moving restricted value.
  • 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.

Sources

  1. Don't Let This Happen to You: Actual Investigations of Export Control and Antiboycott Violations. U.S. Bureau of Industry and Security, Office of Export Enforcement, 2024.
  2. Trade-Based Money Laundering: Risk Indicators. Financial Action Task Force and Egmont Group, 2021.

All glossary terms