Sanctions Evasion Reference

Red-flag indicator library

A red-flag indicator is a published, attributable observation that a transaction warrants further enquiry. This library holds 74, each attributed to the advisory or typology report it comes from.

indicators

74

issuing authorities

4

machine readable

red-flags.json

Every indicator here is quoted or closely paraphrased from a named published document, with the issuing authority, the year and a link to the source. Nothing in this table is this site's own invention.

These are recognition aids, not tests. Almost every indicator has an innocent explanation available, and any one of them standing alone usually means nothing. Their value is cumulative and contextual. Treating a single indicator as proof is the characteristic error of amateur analysis in this field.

74 indicators

Indicators

74 listed
001 A trade entity is registered at what looks like a mass registration address — a post-box, a high-density residential building or a commercial complex with no specific unit given. FATF, 2021
“registered at an address that is likely to be a mass registration address”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. a front company, shell company layering, a professional enabler

002 A newly formed or recently reactivated trade entity suddenly engages in high-volume, high-value trade, in a sector with high barriers to entry. FATF, 2021
“newly formed or recently re-activated trade entity engages in high-volume”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. a front company, a phantom shipment, trade misinvoicing

003 Owners or senior managers appear to be nominees concealing the actual beneficial owners: they lack business management experience, lack knowledge of transaction details, or manage multiple companies. FATF, 2021
“appear to be nominees acting to conceal the actual beneficial owners”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. nominee directors and nominee shareholders, a professional enabler, shell company layering

004 The entity's trade activity is inconsistent with its stated line of business — a car dealer exporting clothing, or a precious metals dealer importing seafood. FATF, 2021
“trade activity is inconsistent with the stated line of business”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. a front company, trade misinvoicing, third-country bank accounts and how are they used

005 The corporate structure is unusually complex and illogical, involving shell companies or companies registered in high-risk jurisdictions. FATF, 2021
“corporate structure of a trade entity appears unusually complex and illogical”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. shell company layering, ownership threshold structuring, a professional enabler

006 Shareholders or directors are formal nominees whose nominator is undisclosed, or informal nominees such as close associates and family. FATF, 2018
“informal nominee shareholders and directors, such as close associates and family”

Source. FATF and Egmont Group, Concealment of Beneficial Ownership (2018). Read the source document.

Appears on. nominee directors and nominee shareholders, ownership threshold structuring, a front company

007 Control over the assets is exercised through third parties — professional intermediaries, family members, associates or nominees — rather than through recorded ownership. FATF, 2018
“control can also be exerted via third parties”

Source. FATF and Egmont Group, Concealment of Beneficial Ownership (2018). Read the source document.

Appears on. nominee directors and nominee shareholders, ownership threshold structuring, shell company layering

008 A jurisdiction permits companies to act as directors without restriction, so no natural person need appear in the filings at all. FATF, 2018
“unrestricted use of legal persons as directors”

Source. FATF and Egmont Group, Concealment of Beneficial Ownership (2018). Read the source document.

Appears on. nominee directors and nominee shareholders, a professional enabler

009 The entity has no online presence, or a website whose content is boilerplate taken from other sites and shows no knowledge of the product or industry it trades in. FATF, 2021
“lacks an online presence”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. a front company, shell company layering, a phantom shipment

010 The entity shows unexplained periods of dormancy, or is not compliant with routine business obligations such as filing VAT returns. FATF, 2021
“unexplained periods of dormancy”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. a front company, shell company layering

011 The entity maintains a minimal number of working staff, inconsistent with the volume of commodities it trades. FATF, 2021
“maintains a minimal number of working staff”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. a front company, trade misinvoicing, a phantom shipment

012 Assets are distributed across multiple companies in multiple jurisdictions, so value passes through several layers of shell companies before reaching its destination. FATF, 2018
“shell companies can be used in complex structures”

Source. FATF and Egmont Group, Concealment of Beneficial Ownership (2018). Read the source document.

Appears on. a front company, shell company layering, nominee directors and nominee shareholders

013 The customer has little or no business background. BIS, 2025
“customer has little or no business background”

Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.

Appears on. a front company, dual-use re-export diversion, end-user certificate fraud

014 A foreign party to the transaction has one or more owners that are listed on the Entity List or the Military End User List. BIS, 2025
“one or more owners that are listed on the entity list”

Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.

Appears on. ownership threshold structuring, a front company, dual-use re-export diversion

015 Invoices or other trade documents show fees or prices out of line with commercial considerations, inconsistent with market value, or fluctuating sharply from comparable past transactions. FATF, 2021
“inconsistent with market value”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. trade misinvoicing, HS code misclassification

016 There are inconsistencies across contracts, invoices and other trade documents — contradictory party names, differing prices, or discrepancies in the quantity, quality, volume or value of the commodities against their descriptions. FATF, 2021
“inconsistencies across contracts, invoices or other trade documents”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. trade misinvoicing, a phantom shipment

017 The value of an entity's registered imports does not match the volume of its foreign bank transfers for imports, or its registered exports do not match incoming foreign transfers. FATF, 2021
“volume of foreign bank transfers”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. trade misinvoicing, a phantom shipment, How is correspondent banking used to evade sanctions

018 Trade documents describe the commodity only generically or non-specifically, in terms too vague to classify or value it. FATF, 2021
“vague descriptions of the traded commodities”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. HS code misclassification, trade misinvoicing

019 Trade or customs documents are missing, appear to be counterfeit, contain false or misleading information, resubmit previously rejected documents, or are frequently modified or amended. FATF, 2021
“appear to be counterfeits”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. HS code misclassification, trade misinvoicing, cargo origin blending

020 Commodities imported under a temporary importation or inward processing regime are subsequently exported with falsified documents. FATF, 2021
“temporary importation and inward processing”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. HS code misclassification, third-country transshipment, cargo origin blending

021 Payment for imported commodities is made by an entity other than the consignee with no clear economic reason — for instance by a shell or front company not party to the trade. FATF, 2021
“payment for imported commodities is made by an entity other than the consignee”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. trade misinvoicing, third-country bank accounts and how are they used, How is correspondent banking used to evade sanctions

022 Shipments are routed through a number of jurisdictions without economic or commercial justification. FATF, 2021
“routed through a number of jurisdictions without economic or commercial justification”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. third-country transshipment, dual-use re-export diversion, cargo origin blending

023 Contracts supporting complex or regular trade are unusually simple, following a sample contract structure available on the internet. FATF, 2021
“follow a “sample contract” structure”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. trade misinvoicing, a phantom shipment, a professional enabler

024 The product's capabilities do not fit the buyer's line of business — the example given is a small bakery ordering several sophisticated lasers. BIS, 2025
“capabilities do not fit the buyer's line of business”

Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.

Appears on. dual-use re-export diversion, end-user certificate fraud, How are aircraft parts procured in breach of sanctions

025 The customer or purchasing agent is reluctant to offer information about the end use of a product. BIS, 2025
“reluctant to offer information about the end-use”

Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.

Appears on. end-user certificate fraud, dual-use re-export diversion

026 The product ordered is incompatible with the technical level of the country it is being shipped to — semiconductor manufacturing equipment to a country with no electronics industry. BIS, 2025
“incompatible with the technical level of the country”

Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.

Appears on. dual-use re-export diversion, third-country transshipment

027 Routine installation, training or maintenance services are declined by the customer. BIS, 2025
“installation, training or maintenance services are declined”

Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.

Appears on. end-user certificate fraud, How are aircraft parts procured in breach of sanctions, dual-use re-export diversion

028 A freight forwarding firm is listed as the product's final destination. BIS, 2025
“freight forwarding firm is listed as the product's final destination”

Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.

Appears on. end-user certificate fraud, third-country transshipment, a professional enabler

029 The customer is willing to pay cash for a very expensive item when the terms of sale call for financing. BIS, 2025
“willing to pay cash for a very expensive item”

Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.

Appears on. dual-use re-export diversion, How are aircraft parts procured in breach of sanctions

030 Packaging is inconsistent with the stated method of shipment or the stated destination. BIS, 2025
“packaging is inconsistent with the stated method of shipment”

Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.

Appears on. dual-use re-export diversion, a phantom shipment, end-user certificate fraud

031 The buyer, when questioned, is evasive or unclear about whether the product is for domestic use, export or re-export. BIS, 2025
“evasive or unclear about whether the purchased product is for domestic use”

Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.

Appears on. end-user certificate fraud, dual-use re-export diversion, How are aircraft parts procured in breach of sanctions

032 The shipping route is abnormal for the product and the destination. BIS, 2025
“shipping route is abnormal for the product and destination”

Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.

Appears on. third-country transshipment, dual-use re-export diversion, HS code misclassification

033 The customer is unfamiliar with the product's performance characteristics but still wants the product. BIS, 2025
“unfamiliar with the product's performance characteristics”

Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.

Appears on. dual-use re-export diversion, end-user certificate fraud

034 Delivery dates are vague, or deliveries are planned for out-of-the-way destinations. BIS, 2025
“delivery dates are vague”

Source. U.S. Bureau of Industry and Security, EAR Supplement No. 3 to Part 732, Red Flags (2025). Read the source document.

Appears on. a phantom shipment, third-country transshipment, end-user certificate fraud

035 An entity purchases commodities allegedly on its own account, but the purchases clearly exceed its economic capabilities and are financed by sudden cash deposits or third-party transfers. FATF, 2021
“purchases clearly exceed the economic capabilities”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. trade misinvoicing, a front company, a phantom shipment

036 A trade entity consistently shows unreasonably low profit margins — importing wholesale commodities at or above retail value, or reselling at or below purchase price. FATF, 2021
“unreasonably low profit margins”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. trade misinvoicing, HS code misclassification

037 The entity engages in complex trade deals involving numerous third-party intermediaries in incongruent lines of business. FATF, 2021
“intermediaries in incongruent lines of business”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. third-country transshipment, a professional enabler, shell company layering

038 AIS data is manipulated so that a ship broadcasts a different name, IMO number, MMSI or other identifying information — a practice referred to as spoofing. OFAC, 2020
“manipulating ais data”

Source. OFAC, State and U.S. Coast Guard, Guidance to Address Illicit Shipping and Sanctions Evasion Practices (2020). Read the source document.

Appears on. AIS manipulation and AIS spoofing, a ship-to-ship transfer

039 Transmitted AIS patterns or data are inconsistent with the ship's actual location. OFAC, 2023
“irregular ais patterns or data that are inconsistent with actual ship locations”

Source. Price Cap Coalition, Price Cap Coalition Advisory for the Maritime Oil Industry (2023). Read the source document.

Appears on. AIS manipulation and AIS spoofing, flag hopping, a ship-to-ship transfer

040 Ship-to-ship transfers are conducted at night or in areas assessed as high risk for sanctions evasion, concealing the origin or destination of the cargo. OFAC, 2020
“ship-to-ship (sts) transfers”

Source. OFAC, State and U.S. Coast Guard, Guidance to Address Illicit Shipping and Sanctions Evasion Practices (2020). Read the source document.

Appears on. a ship-to-ship transfer, cargo origin blending, AIS manipulation and AIS spoofing

041 A ship-to-ship transfer conceals the origin or destination of cargo rather than serving an operational purpose. OFAC, 2019
“sts transfers can conceal the origin or destination of cargo”

Source. OFAC, Syria Shipping Advisory (2019). Read the source document.

Appears on. a ship-to-ship transfer, cargo origin blending

042 A vessel repeatedly registers with new flag states — flag hopping — or falsifies its flag outright to mask illicit trade. OFAC, 2020
“false flags and flag hopping”

Source. OFAC, State and U.S. Coast Guard, Guidance to Address Illicit Shipping and Sanctions Evasion Practices (2020). Read the source document.

Appears on. flag hopping, opaque marine insurance, a ship-to-ship transfer

043 A ship has undergone numerous administrative changes, such as repeated re-flagging. OFAC, 2023
“numerous administrative changes”

Source. Price Cap Coalition, Price Cap Coalition Advisory for the Maritime Oil Industry (2023). Read the source document.

Appears on. flag hopping, opaque marine insurance, shell company layering

044 Vessel names and IMO numbers have been painted over with alternate ones so the ship can pass itself off as a different vessel. OFAC, 2018
“painting over vessel names and imo numbers with alternate ones”

Source. OFAC, North Korea Vessel Advisory (2018). Read the source document.

Appears on. flag hopping, AIS manipulation and AIS spoofing, a ship-to-ship transfer

045 A vessel physically alters the identification it is required to display on its hull or superstructure. OFAC, 2018
“physically altering vessel identification”

Source. OFAC, North Korea Vessel Advisory (2018). Read the source document.

Appears on. AIS manipulation and AIS spoofing, flag hopping

046 Shipping documentation for petrochemicals, petroleum, metals or sand has been falsified in order to disguise the cargo's origin. OFAC, 2020
“in order to disguise their origin”

Source. OFAC, State and U.S. Coast Guard, Guidance to Address Illicit Shipping and Sanctions Evasion Practices (2020). Read the source document.

Appears on. cargo origin blending, trade misinvoicing, third-country transshipment

047 A ship relies on unknown, untested, sporadic or fraudulent insurance, without which it could not meet the costs of an accident or spill. OFAC, 2023
“unknown, untested, sporadic, or fraudulent insurance”

Source. Price Cap Coalition, Price Cap Coalition Advisory for the Maritime Oil Industry (2023). Read the source document.

Appears on. opaque marine insurance, flag hopping, price cap attestation fraud

048 An insurer's financial soundness, track record, regulatory record or ownership structure cannot be established on review. OFAC, 2023
“financial soundness, track record, regulatory record”

Source. Price Cap Coalition, Price Cap Coalition Advisory for the Maritime Oil Industry (2023). Read the source document.

Appears on. opaque marine insurance, price cap attestation fraud

049 Shipping and ancillary costs such as freight, customs and insurance are inflated or bundled, concealing the price actually paid for the oil. OFAC, 2023
“inflation of shipping and ancillary costs”

Source. Price Cap Coalition, Price Cap Coalition Advisory for the Maritime Oil Industry (2023). Read the source document.

Appears on. price cap attestation fraud, trade misinvoicing, opaque marine insurance

050 A counterparty will not provide an itemised breakdown of all costs from which the price paid for the oil could be determined. OFAC, 2023
“itemized breakdown of all costs”

Source. Price Cap Coalition, Price Cap Coalition Advisory for the Maritime Oil Industry (2023). Read the source document.

Appears on. price cap attestation fraud, trade misinvoicing

051 Intermediary companies such as managers, traders or brokerages conceal their beneficial ownership or otherwise engage in unusually opaque practices. OFAC, 2023
“conceal their beneficial ownership”

Source. Price Cap Coalition, Price Cap Coalition Advisory for the Maritime Oil Industry (2023). Read the source document.

Appears on. flag hopping, shell company layering, opaque marine insurance, a front company

052 A vessel navigates suspicious deviations in route — changes with no legitimate reason to go off-route, such as unsafe ports, extreme weather or emergencies. OFAC, 2020
“suspicious deviations in routes”

Source. OFAC, State and U.S. Coast Guard, Guidance to Address Illicit Shipping and Sanctions Evasion Practices (2020). Read the source document.

Appears on. AIS manipulation and AIS spoofing, a ship-to-ship transfer, cargo origin blending

053 Malign actors disguise the ultimate origin or destination of cargo by indirect routing, unscheduled detours, or transit through third countries. OFAC, 2020
“voyage irregularities”

Source. OFAC, State and U.S. Coast Guard, Guidance to Address Illicit Shipping and Sanctions Evasion Practices (2020). Read the source document.

Appears on. AIS manipulation and AIS spoofing, a phantom shipment, cargo origin blending

054 Bills of lading alleging oil, petrochemicals, fuel or metals from areas assessed as high risk for sanctions evasion are presented without further scrutiny of the cargo's origin. OFAC, 2020
“reviewing bills of lading to confirm origin of the cargo”

Source. OFAC, State and U.S. Coast Guard, Guidance to Address Illicit Shipping and Sanctions Evasion Practices (2020). Read the source document.

Appears on. cargo origin blending, trade misinvoicing, a phantom shipment

055 AIS is disabled for periods inconsistent with the safety convention that requires it to be transmitted. OFAC, 2019
“disabling automatic identification system”

Source. OFAC, Syria Shipping Advisory (2019). Read the source document.

Appears on. AIS manipulation and AIS spoofing, a ship-to-ship transfer

056 A respondent provides correspondent banking services onward to other institutions — a downstream, or nested, arrangement — so the correspondent serves customers it never onboarded. Wolfsberg Group, 2022
“downstream fi (also referred to as “nested”)”

Source. The Wolfsberg Group, Wolfsberg Financial Crime Principles for Correspondent Banking (2022). Read the source document.

Appears on. How is correspondent banking used to evade sanctions, third-country bank accounts and how are they used

057 It cannot be determined whether the respondent has controls in place to ensure payment transparency in the services it offers onward. Wolfsberg Group, 2022
“controls are in place to ensure payment transparency”

Source. The Wolfsberg Group, Wolfsberg Financial Crime Principles for Correspondent Banking (2022). Read the source document.

Appears on. How is correspondent banking used to evade sanctions, third-country bank accounts and how are they used

058 An account functions as a pay-through or transit account: rapid movement of high-volume transactions with a small end-of-day balance and no clear business reason. FATF, 2021
“rapid movement of high-volume transactions”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. third-country bank accounts and how are they used, shell company layering, hawala and how does informal value transfer work

059 Incoming wire transfers to a trade-related account are split and forwarded to unrelated accounts with little or no connection to commercial activity. FATF, 2021
“forwarded to non- related multiple accounts”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. third-country bank accounts and how are they used, How is correspondent banking used to evade sanctions, trade misinvoicing

060 Payments are routed in a circle: funds sent from one country and received back in the same country after passing through others. FATF, 2021
“payments are routed in a circle”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. third-country bank accounts and how are they used, hawala and how does informal value transfer work, trade misinvoicing

061 Very late changes are made to payment arrangements — payment redirected to a previously unknown entity at the last moment, or changes to the scheduled date or amount. FATF, 2021
“very late changes to payment arrangements”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. trade misinvoicing, third-country bank accounts and how are they used, How is correspondent banking used to evade sanctions

062 An account shows frequent cash deposits subsequently transferred to persons or entities in free trade zones or offshore jurisdictions with no business relationship to the account holder. FATF, 2021
“frequent deposits in cash”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. hawala and how does informal value transfer work, third-country bank accounts and how are they used, How are gold and commodities used to settle sanctioned trade

063 Brokers settle debts owed to one another by fulfilling the other's commercial obligations — paying a debt or an invoice of the same value — rather than by transferring funds. FATF, 2013
“settle accounts by fulfilling commercial obligations”

Source. FATF, The Role of Hawala and Other Similar Service Providers (2013). Read the source document.

Appears on. hawala and how does informal value transfer work, How are gold and commodities used to settle sanctioned trade, trade misinvoicing

064 Settlement between operators is made through value or cash outside the banking system, including by cash couriers, rather than through traceable transfers. FATF, 2013
“the use of cash couriers”

Source. FATF, The Role of Hawala and Other Similar Service Providers (2013). Read the source document.

Appears on. hawala and how does informal value transfer work, How are gold and commodities used to settle sanctioned trade

065 An operator's settlement commingles licit and illicit proceeds and nets obligations across jurisdictions, masking the individual fund transfers. FATF, 2013
“commingling of licit and illicit proceeds”

Source. FATF, The Role of Hawala and Other Similar Service Providers (2013). Read the source document.

Appears on. hawala and how does informal value transfer work, How are gold and commodities used to settle sanctioned trade, trade misinvoicing

066 The operator's business includes gold dealing alongside money transfer and currency exchange. FATF, 2013
“gold dealing”

Source. FATF, The Role of Hawala and Other Similar Service Providers (2013). Read the source document.

Appears on. hawala and how does informal value transfer work, How are gold and commodities used to settle sanctioned trade

067 An account shows an unexpectedly high number or value of transactions inconsistent with the client's stated business activity. FATF, 2021
“inconsistent with the stated business activity of the client”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. third-country bank accounts and how are they used, trade misinvoicing, How is correspondent banking used to evade sanctions

068 Cash deposits or other transactions are consistently just below the relevant reporting thresholds. FATF, 2021
“consistently just below relevant reporting thresholds”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. third-country bank accounts and how are they used, hawala and how does informal value transfer work

069 Transaction activity associated with a trade entity increases quickly and significantly in volume, then goes dormant after a short period. FATF, 2021
“goes dormant after a short period”

Source. FATF and Egmont Group, Trade-Based Money Laundering: Risk Indicators (2021). Read the source document.

Appears on. a front company, a phantom shipment, third-country bank accounts and how are they used

070 A firm holds internet protocol address information about its users but does not use it to screen for and prevent potential sanctions violations. OFAC, 2021
“did not use the ip address information it collected”

Source. OFAC, Sanctions Compliance Guidance for the Virtual Currency Industry (2021). Read the source document.

Appears on. How is cryptocurrency used to evade sanctions, stablecoin settlement and why does it matter for sanctions, mixers and chain hopping

071 Geolocation tools and IP address blocking controls are not used to identify and prevent access from sanctioned jurisdictions. OFAC, 2021
“geolocation tools and ip address blocking controls”

Source. OFAC, Sanctions Compliance Guidance for the Virtual Currency Industry (2021). Read the source document.

Appears on. How is cryptocurrency used to evade sanctions, stablecoin settlement and why does it matter for sanctions

072 Customer information obtained at onboarding and through the relationship is not used to conduct due diligence sufficient to mitigate sanctions risk. OFAC, 2021
“know your customer (kyc) procedures”

Source. OFAC, Sanctions Compliance Guidance for the Virtual Currency Industry (2021). Read the source document.

Appears on. How is cryptocurrency used to evade sanctions, stablecoin settlement and why does it matter for sanctions, mixers and chain hopping

073 Value moves through anonymity-enhanced cryptocurrencies, mixers and tumblers, decentralised platforms or privacy wallets that reduce transparency and increase obfuscation of financial flows. FATF, 2021
“mixers and tumblers”

Source. FATF, Updated Guidance for a Risk-Based Approach to Virtual Assets and VASPs (2021). Read the source document.

Appears on. mixers and chain hopping, How is cryptocurrency used to evade sanctions, stablecoin settlement and why does it matter for sanctions

074 Products and services are used specifically because they enable or allow for reduced transparency and increased obfuscation of financial flows. FATF, 2021
“reduced transparency and increased obfuscation”

Source. FATF, Updated Guidance for a Risk-Based Approach to Virtual Assets and VASPs (2021). Read the source document.

Appears on. mixers and chain hopping, How is cryptocurrency used to evade sanctions