[{"t":"What is AIS manipulation and AIS spoofing?","d":"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.","u":"/techniques/ais-manipulation/","k":"Technique","x":"AIS spoofing going dark transponder manipulation dark activity"},{"t":"What is dual-use re-export diversion?","d":"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.","u":"/techniques/dual-use-re-export/","k":"Technique","x":"diversion procurement network activity re-export diversion"},{"t":"How is correspondent banking used to evade sanctions?","d":"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.","u":"/techniques/correspondent-banking-abuse/","k":"Technique","x":"nested correspondent abuse downstream clearing abuse"},{"t":"How are aircraft parts procured in breach of sanctions?","d":"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.","u":"/techniques/aviation-parts-procurement/","k":"Technique","x":"aircraft parts diversion aviation procurement networks"},{"t":"What is a front company?","d":"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.","u":"/techniques/front-companies/","k":"Technique","x":"front cover company proxy company"},{"t":"What is end-user certificate fraud?","d":"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.","u":"/techniques/end-user-certificate-fraud/","k":"Technique","x":"end-use fraud EUC fraud false end-user statements"},{"t":"How are gold and commodities used to settle sanctioned trade?","d":"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.","u":"/techniques/gold-and-commodity-barter/","k":"Technique","x":"gold settlement barter trade commodity-for-oil"},{"t":"What is flag hopping?","d":"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.","u":"/techniques/flag-hopping/","k":"Technique","x":"flag shopping reflagging registry hopping"},{"t":"What is cargo origin blending?","d":"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.","u":"/techniques/cargo-origin-blending/","k":"Technique","x":"origin laundering cargo blending commingling"},{"t":"How is cryptocurrency used to evade sanctions?","d":"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.","u":"/techniques/crypto-rails/","k":"Technique","x":"virtual currency settlement digital asset rails"},{"t":"What is HS code misclassification?","d":"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.","u":"/techniques/hs-code-misclassification/","k":"Technique","x":"tariff misclassification commodity code fraud"},{"t":"What is hawala and how does informal value transfer work?","d":"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.","u":"/techniques/hawala-and-informal-value-transfer/","k":"Technique","x":"hundi IVTS informal value transfer"},{"t":"What are nominee directors and nominee shareholders?","d":"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.","u":"/techniques/nominee-directors/","k":"Technique","x":"nominee shareholders straw directors proxy officers"},{"t":"What are mixers and chain hopping?","d":"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.","u":"/techniques/mixers-and-chain-hopping/","k":"Technique","x":"tumblers cross-chain hopping obfuscation services"},{"t":"What is opaque marine insurance?","d":"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.","u":"/techniques/opaque-marine-insurance/","k":"Technique","x":"unverifiable P&I shadow insurance sham cover"},{"t":"What is a professional enabler?","d":"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.","u":"/techniques/professional-enablers/","k":"Technique","x":"gatekeepers professional facilitators TCSPs"},{"t":"What is ownership threshold structuring?","d":"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.","u":"/techniques/ownership-threshold-structuring/","k":"Technique","x":"49 percent structuring threshold structuring dilution"},{"t":"What is price cap attestation fraud?","d":"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.","u":"/techniques/price-cap-attestation-fraud/","k":"Technique","x":"attestation fraud price cap circumvention"},{"t":"What is a phantom shipment?","d":"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.","u":"/techniques/phantom-shipments/","k":"Technique","x":"fictitious trade ghost shipments paper trades"},{"t":"What is shell company layering?","d":"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.","u":"/techniques/shell-company-layering/","k":"Technique","x":"corporate layering chain structures stacked ownership"},{"t":"What is stablecoin settlement and why does it matter for sanctions?","d":"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.","u":"/techniques/stablecoin-settlement/","k":"Technique","x":"tether settlement digital dollar settlement"},{"t":"What is a ship-to-ship transfer?","d":"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.","u":"/techniques/ship-to-ship-transfers/","k":"Technique","x":"STS transfers lightering at-sea transfers"},{"t":"What are third-country bank accounts and how are they used?","d":"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.","u":"/techniques/third-country-bank-accounts/","k":"Technique","x":"proxy accounts conduit accounts third-jurisdiction banking"},{"t":"What is third-country transshipment?","d":"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.","u":"/techniques/third-country-transshipment/","k":"Technique","x":"transshipment diversion indirect export re-routing"},{"t":"What is trade misinvoicing?","d":"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.","u":"/techniques/trade-misinvoicing/","k":"Technique","x":"misinvoicing over-invoicing under-invoicing trade fraud"},{"t":"How are omnibus securities accounts used to evade sanctions?","d":"Holding a sanctioned party's securities in a custodian's own name inside a pooled account shared with other clients, so the institution that can screen and block never sees who actually owns the position.","u":"/techniques/omnibus-securities-accounts/","k":"Technique","x":"nominee account abuse custody chain layering"},{"t":"How do gaps in acquisition integration create sanctions exposure?","d":"A company buys a foreign business and keeps running its systems separately, so the acquired unit's transactions never pass through the parent's sanctions screening until someone thinks to connect them.","u":"/techniques/acquisition-integration-gaps/","k":"Technique","x":"M&A integration gap unintegrated subsidiary exposure"},{"t":"What happens when sanctions-screening controls go untested?","d":"A firm builds real geo-blocking or screening controls, then never independently tests whether they still work, so a bug, a disabled setting or a discontinued tool runs unnoticed for months or years.","u":"/techniques/untested-screening-controls/","k":"Technique","x":"control decay silent screening failure"},{"t":"Adani Enterprises: 35 cargoes of LPG that were not Omani","d":"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.","u":"/cases/adani-enterprises-lpg/","k":"Case","x":"Adani Enterprises Limited Adani Ports and Special Economic Zone Ltd"},{"t":"Citibank London: 970 payments, one missed prefix","d":"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.","u":"/cases/cbna-london-2026/","k":"Case","x":"Citibank, N.A., London Branch Citi"},{"t":"Binance: a matching engine with no jurisdiction in it","d":"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.","u":"/cases/binance-2023/","k":"Case","x":"Binance Holdings, Ltd."},{"t":"British American Tobacco and the North Korea joint venture","d":"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.","u":"/cases/british-american-tobacco-dprk/","k":"Case","x":"British American Tobacco p.l.c. British-American Tobacco Marketing (Singapore) PTE Ltd"},{"t":"Bittrex: onboarding data collected and not screened","d":"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.","u":"/cases/bittrex-2022/","k":"Case","x":"Bittrex, Inc."},{"t":"Clearstream: one layer deeper in the custody chain","d":"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.","u":"/cases/clearstream-2014/","k":"Case","x":"Clearstream Banking S.A. Central Bank of Iran"},{"t":"Commerzbank: a manual payment queue for Iranian counterparties","d":"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.","u":"/cases/commerzbank-2015/","k":"Case","x":"Commerzbank AG"},{"t":"Epsilon Electronics: selling to a distributor that sold to Iran","d":"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.","u":"/cases/epsilon-electronics-iran/","k":"Case","x":"Epsilon Electronics, Inc. Asra International LLC"},{"t":"BNP Paribas: the $963m correspondent banking settlement","d":"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.","u":"/cases/bnp-paribas-2014/","k":"Case","x":"BNP Paribas SA"},{"t":"Essentra FZE: cigarette filters to North Korea through front companies","d":"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.","u":"/cases/essentra-fze-dprk/","k":"Case","x":"Essentra FZE Company Limited"},{"t":"Family International Realty: transferred to relatives","d":"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.","u":"/cases/family-international-realty/","k":"Case","x":"Family International Realty LLC Valeri Abramov Viktor Perevalov Roman Sinyavsky"},{"t":"Fokker Services: 1,153 shipments of aircraft parts to Iran and Sudan","d":"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.","u":"/cases/fokker-services-aircraft-parts/","k":"Case","x":"Fokker Services B.V."},{"t":"Halkbank, Zarrab and Atilla: oil revenue disguised as food","d":"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.","u":"/cases/halkbank-zarrab-atilla/","k":"Case","x":"Mehmet Hakan Atilla Reza Zarrab Türkiye Halk Bankasi A.S. Central Bank of Iran National Iranian Oil Company"},{"t":"Flighttime: a false end-user certificate","d":"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.","u":"/cases/flighttime-enterprises-aviation/","k":"Case","x":"Flighttime Enterprises Inc. Daniela Friery Pavil Iglin Marat Aysin"},{"t":"GVA Capital: managed through a nephew","d":"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.","u":"/cases/gva-capital-kerimov/","k":"Case","x":"GVA Capital Ltd. Suleiman Kerimov Nariman Gadzhiev Heritage Trust"},{"t":"MID-SHIP Group: payments connected to blocked vessels","d":"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.","u":"/cases/mid-ship-group-irisl/","k":"Case","x":"MID-SHIP Group LLC Islamic Republic of Iran Shipping Lines"},{"t":"Herbert Smith Freehills Moscow: six payments while closing the office","d":"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.","u":"/cases/hsf-moscow-2024/","k":"Case","x":"Herbert Smith Freehills CIS LLP Herbert Smith Freehills LLP"},{"t":"Nordgas: re-exporting US pressure switches to Iran","d":"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.","u":"/cases/nordgas-iran-reexport/","k":"Case","x":"Nordgas S.r.l."},{"t":"Insurance against a risk the seller creates","d":"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.","u":"/cases/hormuz-marine-insurance/","k":"Case","x":"Persian Gulf Marine Insurance Company HormuzSafe Marine Services Authority Islamic Revolutionary Guard Corps"},{"t":"Blender, Tornado Cash and Sinbad: designating the mixers","d":"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.","u":"/cases/mixer-designations/","k":"Case","x":"Blender.io Tornado Cash Sinbad.io Lazarus Group"},{"t":"Lumber Marine and Ice Pearl: the first price cap designations","d":"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.","u":"/cases/price-cap-first-designations/","k":"Case","x":"Lumber Marine SA Ice Pearl Navigation Corp"},{"t":"Sojitz Hong Kong: dollar payments for Iranian-origin polyethylene","d":"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.","u":"/cases/sojitz-hong-kong-iran-hdpe/","k":"Case","x":"Sojitz (Hong Kong) Limited"},{"t":"Swedbank Latvia: a client banking from Crimea","d":"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.","u":"/cases/swedbank-latvia-crimea/","k":"Case","x":"Swedbank AS (Latvia)"},{"t":"Toll Holdings: a freight forwarder's 2,958 payments","d":"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.","u":"/cases/toll-holdings-freight-forwarding/","k":"Case","x":"Toll Holdings Limited"},{"t":"TGR Group: cash in one city, USDT in another","d":"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.","u":"/cases/tgr-group-usdt/","k":"Case","x":"TGR Group George Rossi Elena Chirkinyan Ekaterina Zhdanova TGR Corporate Concierge LTD"},{"t":"Standard Chartered: 9,335 payments from accounts in Dubai","d":"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.","u":"/cases/standard-chartered-2019/","k":"Case","x":"Standard Chartered Bank Standard Chartered Bank Dubai"},{"t":"ZTE: front companies and an internal plan to keep supplying Iran","d":"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.","u":"/cases/zte-2017/","k":"Case","x":"Zhongxing Telecommunications Equipment Corporation ZTE Kangxun Telecommunications Ltd"},{"t":"Deutsche Bank London: a screening list with no ownership data","d":"Deutsche Bank's London branch paid £635,618.75 in two payments to Okko, a Russian streaming company sold by Sberbank to an entity designated weeks later. Screening lists carried no ownership data. OFSI settled at £165,000.","u":"/cases/deutsche-bank-london-2026/","k":"Case","x":"Deutsche Bank AG London Branch Okko LLC JSC New Opportunities PJSC Sberbank"},{"t":"Markom Management: an overpayment returned to a designated person","d":"A UK fiduciary services firm instructed a £416,590.92 refund to a designated person after an overpayment, in haste and without legal advice. OFSI penalised it £300,000 in 2025, reduced from a proposed £400,000.","u":"/cases/markom-management-2025/","k":"Case","x":"Markom Management Limited Markom Management Cyprus"},{"t":"Sabre: a $200 test payment through a second bank","d":"A UK travel-technology company kept serving and invoicing Ural Airlines after its designation, then tested whether payments would clear through its US bank after its UK bank froze them. OFSI penalised it £1,000,920.59.","u":"/cases/sabre-global-2026/","k":"Case","x":"Sabre Global Technologies Limited JSC Ural Airlines"},{"t":"Standard Chartered UK: 70 loans to a Sberbank subsidiary","d":"OFSI penalised Standard Chartered £20.47m in 2020 over loans to Denizbank, a Turkish bank almost wholly owned by Sberbank, that did not qualify for the EU-nexus exemption. Ministerial review cut the earlier £31.5m.","u":"/cases/standard-chartered-uk-2020/","k":"Case","x":"Standard Chartered Bank Denizbank A.Ş. Sberbank of Russia"},{"t":"Rotterdam: components invoiced to the Maldives","d":"A Dutch court fined an electronics company €200,000 and jailed its Russian-born director for 18 months in 2023 over integrated circuits sent to Russia, on eight invoices naming a Maldives transhipment firm as the customer.","u":"/cases/rotterdam-electronics-maldives-2023/","k":"Case","x":"A Dutch electronics company (name withheld in the judgment) Its Russian-born managing director"},{"t":"Aiotec: a polypropylene plant declared for Türkiye, delivered to Iran","d":"A German company paid OFAC $14.55m in 2024 after buying a decommissioned Australian plant through a US reseller and shipping it to Iran, using three end-user certificates naming Türkiye and shipping documents that showed the UAE and Mersin.","u":"/cases/aiotec-iran-polypropylene-plant/","k":"Case","x":"Aiotec GmbH Aiotec Middle East Co."},{"t":"SCG Plastics: Iranian resin with the origin 'Middle East'","d":"A Thai trading company paid OFAC $20m in 2024 after selling Iranian-made polyethylene for dollars, listing the country of origin as 'Middle East' and the loading port as Jebel Ali, so that US correspondent banks processed $291m.","u":"/cases/scg-plastics-iranian-hdpe/","k":"Case","x":"SCG Plastics Co., Ltd. Mehr Petrochemical Company"},{"t":"Keystone Shipping: Russian bitumen via sham sales chains","d":"An Estonian court convicted a trading company and its board member in 2026 for buying Russian bitumen through a chain of sham sales and forged Kazakh and Uzbek export papers, and for buying from a state-owned Gazprom Neft subsidiary.","u":"/cases/keystone-shipping-estonia-2026/","k":"Case","x":"Keystone Shipping OÜ Andrey Kolesnikov"},{"t":"A €62,000 car declared at €4,900","d":"Estonian courts convicted two men of attempting to export a luxury car to Russia in 2023. The papers said €4,900 and 'unroadworthy'. The purchase price was €59,571 and the valuation €62,000, above the €50,000 ban threshold.","u":"/cases/estonia-luxury-car-narva-2023/","k":"Case","x":"Two Russian citizens, one owning a Czech company, convicted in Estonia"},{"t":"Estonia: a media network kept running after it 'closed'","d":"An Estonian court convicted a resident in 2025 of breaching EU sanctions by continuing a designated Russian media head's Estonian operation through a renamed company, a new brand, a nonprofit and Russian funding after its office formally closed.","u":"/cases/estonia-media-representation-2025/","k":"Case","x":"An Estonian resident convicted as co-perpetrator, with a spouse"},{"t":"Lübeck: 16,000 deliveries to Russian defence companies alleged","d":"German federal prosecutors arrested five people in February 2026 on suspicion of running a criminal organisation that exported goods to Russia through a Lübeck trading company, a shell company and fictitious customers, including to 24 listed defence firms.","u":"/cases/luebeck-export-network-2026/","k":"Case","x":"A Lübeck trading company and its managing director A second shell company in Lübeck"},{"t":"Netherlands: lab equipment exported through a web of firms","d":"Five countries' authorities arrested three people in January 2024 over technological and laboratory equipment with military uses exported to Russia through a web of enterprises around a Dutch trading company, now run from Russia.","u":"/cases/netherlands-lab-equipment-network-2024/","k":"Case","x":"A Dutch-registered trading company set up in 2017 Two of its administrators An employee of an external contractor"},{"t":"Exodus: support staff who suggested a VPN","d":"A US crypto-wallet company paid OFAC $3.1m in 2025 for 254 customer-support contacts with users in Iran, on 12 of which staff who knew the exchange partner was blocking Iran recommended VPNs to hide the users' location.","u":"/cases/exodus-wallet-iran-vpn-2025/","k":"Case","x":"Exodus Movement, Inc."},{"t":"Gracetown: payments for a designated oligarch's former company","d":"OFAC fined a New York property manager $7.1m in 2025 for taking 24 payments on behalf of a company owned by Oleg Deripaska after his designation, and for not reporting the blocked debt for over 45 months.","u":"/cases/gracetown-deripaska-2025/","k":"Case","x":"Gracetown, Inc. Baufinanz"},{"t":"Haas: unlock codes for machines owned by blocked Russian entities","d":"A California machine-tool maker paid OFAC $1.04m in 2025 after its Russian distributor sold a CNC machine and parts to eight blocked or majority-owned customers and obtained unlock codes that kept their machines running.","u":"/cases/haas-automation-russia-2025/","k":"Case","x":"Haas Automation, Inc. Abamet Management Limited"},{"t":"Harman: 'North Dubai' as a code for Iran","d":"A US audio company paid OFAC $1.45m in 2025 after 13 sales employees knew its UAE distributor was reselling to Iran and referred to it in emails as 'the northern region', 'North Dubai' and 'up north'.","u":"/cases/harman-uae-distributor-iran-2025/","k":"Case","x":"Harman International Industries, Inc. Harman Professional, Inc."},{"t":"Mondo TV: paying a North Korean studio through a US company","d":"An Italian animation company paid OFAC $538,000 in 2024 after making 18 payments to a North Korean government studio through two Chinese firms and a US company's American bank accounts, on the studio's invoices.","u":"/cases/mondo-tv-north-korea-2024/","k":"Case","x":"Mondo TV, S.p.a."},{"t":"ShapeShift: 17,183 exchanges with users in sanctioned countries","d":"A Swiss-incorporated, Denver-run crypto exchange paid OFAC $750,000 in 2025 for exchanging $12.6m of digital assets with users in Cuba, Iran, Sudan and Syria, having collected IP addresses but never screened them.","u":"/cases/shapeshift-exchange-2025/","k":"Case","x":"ShapeShift AG"},{"t":"SkyGeek: a $669 refund to a newly designated UAE supplier","d":"A New York aviation-parts seller paid OFAC $22,172 in 2024 for two attempted refunds and four shipments to two UAE aircraft-parts firms designated for Russian sectors, after its screening did not re-run on customers already approved.","u":"/cases/skygeek-refunds-to-sdns-2024/","k":"Case","x":"SkyGeek Logistics, Inc."},{"t":"Vietnam Beverage: alcohol to North Korea, paid by 17 firms","d":"A Vietnamese drinks holding company paid OFAC $860,000 in 2024 after its subsidiaries invoiced North Korean buyers in dollars and were paid by 15 third-party companies in Hong Kong, China and Turkey, plus two more in Singapore and the Seychelles.","u":"/cases/vietnam-beverage-north-korea-2024/","k":"Case","x":"Vietnam Beverage Company Limited"},{"t":"C.H. Robinson: five subsidiaries not yet on the parent's screening","d":"A Minnesota logistics company paid OFAC $257,690 in 2024 after five acquired foreign subsidiaries brokered or moved 82 shipments to or from Iran, or of Iranian or Cuban goods, on systems the parent had not yet connected.","u":"/cases/ch-robinson-subsidiaries-2024/","k":"Case","x":"C.H. Robinson International Inc."},{"t":"EFG: blocked clients behind an omnibus account","d":"A Swiss private bank paid OFAC $3.7m in 2024 after its subsidiaries processed 873 securities transactions through omnibus accounts at US custodians for Cuban residents and two designated clients, without telling the US firms who was behind the account.","u":"/cases/efg-omnibus-accounts-2024/","k":"Case","x":"EFG International AG EFG Miami EFG Singapore"},{"t":"IMG Academy: tuition paid by third parties for two designated parents","d":"A Florida sports academy paid OFAC $1.72m in 2026 after enrolling the children of two individuals designated for cartel ties over five years, with tuition wired by non-designated third parties, mostly in Mexico.","u":"/cases/img-academy-tuition-2026/","k":"Case","x":"IMG Academy, LLC"},{"t":"IPI Partners: a legal opinion built on half the facts","d":"A Chicago private equity firm paid OFAC $11.5 million in 2025 for continuing to deal with the same Kerimov trust structure GVA Capital used, after its own outside counsel cleared the account on incomplete information.","u":"/cases/ipi-partners-kerimov-2025/","k":"Case","x":"IPI Partners, LLC Suleiman Kerimov Nariman Gadzhiev Definition Services, Inc. Heritage Trust"},{"t":"Interactive Brokers: six failures across one platform","d":"A global online broker paid OFAC $11.8 million in 2025 after geo-blocking gaps, a mis-dispositioned SDN alert, an unscreened liquidation engine and an ownership-lookup delay let six different sanctions programs be breached.","u":"/cases/interactive-brokers-2025/","k":"Case","x":"Interactive Brokers LLC"},{"t":"Key Holding: found during due diligence for the next sale","d":"A Delaware logistics company paid OFAC $608,825 in 2025 after its Colombian subsidiary ran 36 freight shipments to Cuba, discovered only when the parent was vetting the subsidiary for resale to another buyer.","u":"/cases/key-holding-colombia-cuba-2025/","k":"Case","x":"Key Holding, LLC Key Logistics Colombia S.A.S."},{"t":"Rice Lake Weighing Systems: one email, no translation","d":"A Wisconsin manufacturer paid OFAC $60,764 in 2026 after its Italian subsidiary, told once by email to stop dealing with Iran, kept selling through a UAE distributor whose customer's emails were signed from Iran.","u":"/cases/rice-lake-weighing-iran-2026/","k":"Case","x":"Rice Lake Weighing Systems Dini Argeo S.r.l. Pand Weighing Control"},{"t":"TradeStation: two layers of geo-blocking, both down","d":"A Florida brokerage paid OFAC $1.1 million in 2026 after a platform rebuild, an unreset setting and a discontinued test tool let its two-layer geo-blocking system fail for nearly a year without anyone noticing.","u":"/cases/tradestation-securities-2026/","k":"Case","x":"TradeStation Securities, Inc."},{"t":"Apple Distribution International: an ownership change nobody caught","d":"Apple's Irish payments subsidiary paid OFSI £390,000 in 2026, the first case under OFSI's new settlement framework, after paying a Russian app developer that had quietly changed hands to a newly designated owner.","u":"/cases/apple-distribution-international-2026/","k":"Case","x":"Apple Distribution International Limited (ADI) Okko LLC JSC New Opportunities PJSC Sberbank"},{"t":"Herbert Smith Freehills Moscow: six payments in a rushed closure","d":"A Magic Circle law firm's Russian office paid OFSI £465,000 in 2025 after making six payments to designated banks while closing down in a week, including one to a subsidiary its own staff wrongly cleared.","u":"/cases/hsf-moscow-2025/","k":"Case","x":"Herbert Smith Freehills CIS LLP (HSF Moscow) Herbert Smith Freehills LLP (HSF London)"},{"t":"Murad: hidden from the acquirer, before and after the deal","d":"A cosmetics company and a former executive paid OFAC $3.5 million combined in 2023 for an eight-year Iran export conspiracy concealed from Unilever during its 2015 acquisition and continued for over two years afterward despite direct instructions to stop.","u":"/cases/murad-unilever-iran-2023/","k":"Case","x":"Murad, LLC Unilever United States, Inc. A former senior executive (\"U.S. Person-1\")"},{"t":"Nasdaq: an Iranian bank on the member list nobody read sanctions into","d":"Nasdaq paid OFAC $4 million in 2023: its Armenian exchange subsidiary, inherited via a 2008 acquisition, kept an Iranian-owned bank's market access running for two years after staff were twice told who the member was.","u":"/cases/nasdaq-armenia-bank-mellat-2023/","k":"Case","x":"Nasdaq, Inc. Nasdaq OMX Armenia OJSC Mellat Bank SB CJSC (Mellat Armenia)"},{"t":"State Street: redated invoices inside an acquisition","d":"State Street paid OFAC $7.5 million in 2024 after its acquired subsidiary kept redating invoices to dodge Russia's debt-maturity sanctions for two years post-acquisition, while State Street's own screening alerts on the same payments were manually dismissed.","u":"/cases/state-street-charles-river-2024/","k":"Case","x":"State Street Bank and Trust Company Charles River Systems, Inc. PJSC Sberbank VTB Bank"},{"t":"Wells Fargo: software built to host what the bank wouldn't process","d":"Wells Fargo paid OFAC $30 million in 2023 after inheriting a Wachovia platform specially engineered so a European bank could process trade-finance deals with Iran, Sudan and Syria on infrastructure the US bank still controlled.","u":"/cases/wells-fargo-wachovia-eximbills-2023/","k":"Case","x":"Wachovia Bank Wells Fargo Bank, N.A. A European bank (\"Bank A\")"},{"t":"Bukit Muria Jaya: cigarette paper for North Korea, paid in dollars","d":"An Indonesian paper manufacturer paid OFAC $1.0 million in 2021 after selling cigarette paper to North Korea, swapping DPRK names for intermediaries on its paperwork and taking payment through a dollar account that cleared in the US.","u":"/cases/bukit-muria-jaya-dprk-2021/","k":"Case","x":"PT Bukit Muria Jaya (BMJ) Korea Daesong General Trading Corporation"},{"t":"Danfoss: paid through a US bank's UAE branch","d":"Danish manufacturer Danfoss paid OFAC $4.4 million in 2022 after its UAE subsidiary told customers in Iran, Syria and Sudan to pay into a US bank's UAE branch, using money exchangers as third-party payers.","u":"/cases/danfoss-uae-us-branch-account-2022/","k":"Case","x":"Danfoss A/S Danfoss FZCO"},{"t":"Fracht: a charter on a blocked Mahan Air aircraft","d":"A Houston freight forwarder paid OFAC $1.6 million in 2025 after two executives skipped screening to charter a Venezuelan state airline's aircraft, which was still blocked as Mahan Air property under its old Iranian tail number.","u":"/cases/fracht-emtrasur-mahan-air-2025/","k":"Case","x":"Fracht FWO Inc. Empresa de Transporte Aéreocargo del Sur S.A. (EMTRASUR) Consorcio Venezolano de Industrias Aeronáuticas y Servicios Aéreos (CONVIASA) Mahan Air"},{"t":"UniCredit: a written guide to payments the US would not see","d":"Three UniCredit banks paid OFAC $611 million in 2019 across 2,897 apparent violations, including a formal guide telling staff how to format dollar payments so US intermediaries could not detect sanctioned parties.","u":"/cases/unicredit-2019/","k":"Case","x":"UniCredit Bank AG UniCredit Bank Austria AG UniCredit S.p.A. Islamic Republic of Iran Shipping Lines (IRISL)"},{"t":"Unicat: Iran written as \"I\" in the emails","d":"A Texas catalyst company paid OFAC $3.9 million in 2025 after its former CEO directed sales to Iran through a UAE distributor, a Dutch affiliate and a China office. New owners found it on a site visit.","u":"/cases/unicat-catalysts-iran-venezuela-2025/","k":"Case","x":"Unicat Catalyst Technologies, LLC Its former chief executive officer Unicat's Dutch affiliate Orinoco Iron S.C.S."},{"t":"UBAF: Syrian transfers booked inside, mirrored in dollars","d":"A French trade-finance bank settled with OFAC in 2021 for processing 127 transactions worth $2.1 billion for Syrian parties by booking internal transfers and then clearing near-identical dollar payments for other clients through a US bank.","u":"/cases/ubaf-syria-internal-transfers-2021/","k":"Case","x":"Union de Banques Arabes et Françaises (UBAF)"},{"t":"Crédit Agricole: Sudan through the Swiss subsidiary","d":"Crédit Agricole CIB paid OFAC $329.6 million in 2015 for 4,297 violations, almost all Sudanese. Its Swiss subsidiary and predecessors processed 4,024 of the 4,055 Sudan transfers, omitting sanctioned parties from SWIFT messages.","u":"/cases/credit-agricole-cib-2015/","k":"Case","x":"Crédit Agricole Corporate and Investment Bank (CA-CIB) Crédit Agricole (Suisse) S.A. Crédit Lyonnais (Suisse) S.A."},{"t":"Credit Suisse: standard procedures for cover payments","d":"Credit Suisse paid $536 million in 2009 in a global settlement. OFAC found the bank had standard procedures for cover payments and altered messages that hid sanctioned parties across 5,138 transfers.","u":"/cases/credit-suisse-2009/","k":"Case","x":"Credit Suisse AG Credit Suisse Asset Management London Credit Suisse Securities (USA) LLC"},{"t":"ExxonMobil: eight documents signed with Igor Sechin","d":"ExxonMobil is the company OFAC fined $2 million in 2017 for signing eight oil and gas documents with Rosneft's chief, Igor Sechin, after his designation. A federal court vacated the penalty in 2019.","u":"/cases/exxonmobil-sechin-2017/","k":"Case","x":"ExxonMobil Corporation ExxonMobil Development Company ExxonMobil Oil Corporation Igor Sechin Rosneft OAO"},{"t":"HSBC: Burma and Sudan, not just Iran","d":"HSBC paid OFAC $375 million in 2012. The sanctions case covered 2,335 transfers worth about $430 million, with Burma the largest share, and Treasury said its London head office and Dubai branch altered SWIFT messages.","u":"/cases/hsbc-2012/","k":"Case","x":"HSBC Holdings plc HSBC Bank USA, N.A. HSBC Group's London head office and Dubai branch"},{"t":"ING: 20,452 Cuba transactions, run from the branches","d":"ING Bank paid OFAC $619 million in 2012 over mostly Cuban dollar transactions. Treasury said senior managers told staff in Curaçao to omit Cuba from payment messages, and a French office authorised false endorsement stamps.","u":"/cases/ing-bank-2012/","k":"Case","x":"ING Bank N.V."},{"t":"Maersk Line, Limited: 4,714 shipments booked by the group","d":"Maersk Line, Limited, a US subsidiary, paid OFAC $3.1 million in 2010 for shipping services on 4,714 cargoes to or from Sudan and Iran, carried on its vessels but booked through its non-US parent.","u":"/cases/maersk-line-limited-2010/","k":"Case","x":"Maersk Line, Limited Farrell Lines Incorporated E-Ships, Inc. A.P. Moller-Maersk A/S"},{"t":"Balli Aviation: three airliners for Mahan Air","d":"Balli Aviation is the London company that paid $15 million with Balli Group in 2010, and pleaded guilty, after exporting three commercial airliners from the United States to Iran's Mahan Airlines and attempting three more.","u":"/cases/balli-aviation-mahan-air-2010/","k":"Case","x":"Balli Group PLC Balli Aviation, Ltd. Mahan Airlines"},{"t":"Bank of Moscow: Bank Melli Iran as 'BMI CJSC'","d":"Bank of Moscow is the Russian bank that paid OFAC $9.5 million in 2014 for 69 dollar transfers worth $41 million for a designated Iranian bank's Moscow subsidiary, named by abbreviation so US banks processed them without review.","u":"/cases/bank-of-moscow-2014/","k":"Case","x":"Joint-Stock Commercial Bank \"Bank of Moscow\" Bank Melli Iran ZAO, Moscow (BMI Russia)"},{"t":"Berkshire Hathaway: a Turkish subsidiary hid Iran sales","d":"Berkshire Hathaway paid OFAC $4.1 million in 2020 after its Turkish cutting-tool subsidiary sold to Iran through two Turkish distributors, using private email accounts, false names and false invoices to hide it from the group.","u":"/cases/berkshire-hathaway-iscar-turkey-2020/","k":"Case","x":"Berkshire Hathaway Inc. Iscar Kesici Takim Ticareti ve Imalati Limited Sirket (Iscar Turkey)"},{"t":"Barclays: memos warned of a 'work around'","d":"Barclays paid OFAC $176 million in 2010. The settlement agreement quotes internal memos from 2001 and 2004 warning that its payment procedures were a work around of US sanctions, and cover payments a way of bypassing them.","u":"/cases/barclays-2010/","k":"Case","x":"Barclays Bank PLC Barclays Bank PLC, New York"},{"t":"CSE TransTel: a promise to its bank, broken in two months","d":"Singapore's CSE TransTel paid OFAC $12 million in 2017. Two months after promising its bank not to route Iran business through it, it sent 104 dollar transfers for Iranian energy projects that cleared through US banks.","u":"/cases/cse-global-transtel-2017/","k":"Case","x":"CSE TransTel Pte. Ltd. CSE Global Limited"},{"t":"Lloyds TSB: a policy of deleting sanctioned names","d":"Lloyds TSB paid $217 million in 2009 although OFAC counted only $37 million in transfers. OFAC says it had a policy of intentionally manipulating and deleting information about sanctioned parties in wire instructions.","u":"/cases/lloyds-tsb-2009/","k":"Case","x":"Lloyds TSB Bank, plc"},{"t":"Standard Chartered 2012: Sudan largest, all self-disclosed","d":"Standard Chartered paid OFAC $132 million in 2012 over 919 wire transfers across five programmes. Sudan carried 52 per cent of the base penalty, and the bank had voluntarily self-disclosed all of it.","u":"/cases/standard-chartered-2012/","k":"Case","x":"Standard Chartered Bank"},{"t":"Automatic Identification System","d":"A mandatory maritime transponder system that broadcasts a vessel's identity, position, course and speed to nearby vessels and shore stations.","u":"/reference/glossary/ais/","k":"Glossary","x":"AIS"},{"t":"Asset freeze","d":"The prohibition on dealing with funds or economic resources owned, held or controlled by a designated person, and on making funds available to them.","u":"/reference/glossary/asset-freeze/","k":"Glossary","x":""},{"t":"Blockchain analytics","d":"The practice of clustering addresses and attributing them to real-world services or actors, using on-chain patterns and off-chain information.","u":"/reference/glossary/blockchain-analytics/","k":"Glossary","x":""},{"t":"Bill of lading","d":"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.","u":"/reference/glossary/bill-of-lading/","k":"Glossary","x":"B/L"},{"t":"Beneficial owner","d":"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.","u":"/reference/glossary/beneficial-owner/","k":"Glossary","x":"ultimate beneficial owner UBO"},{"t":"Attestation","d":"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.","u":"/reference/glossary/attestation/","k":"Glossary","x":""},{"t":"Chain hopping","d":"Moving value rapidly between different blockchains, usually through bridges or swap services, to interrupt tracing that works within a single chain.","u":"/reference/glossary/chain-hopping/","k":"Glossary","x":"cross-chain hopping bridging"},{"t":"Blocked property","d":"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.","u":"/reference/glossary/blocked-property/","k":"Glossary","x":""},{"t":"Blocking","d":"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.","u":"/reference/glossary/blocking/","k":"Glossary","x":"freezing"},{"t":"Certificate of origin","d":"A document certifying the country in which goods were produced, used to determine tariff treatment and whether origin-based restrictions apply.","u":"/reference/glossary/certificate-of-origin/","k":"Glossary","x":""},{"t":"Customer due diligence","d":"The ongoing process of understanding a customer's identity, ownership, expected activity and risk, and checking that actual activity remains consistent with it.","u":"/reference/glossary/customer-due-diligence/","k":"Glossary","x":"CDD"},{"t":"Correspondent banking","d":"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.","u":"/reference/glossary/correspondent-banking/","k":"Glossary","x":"correspondent account nostro/vostro"},{"t":"De minimis rule","d":"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.","u":"/reference/glossary/de-minimis-rule/","k":"Glossary","x":""},{"t":"Corporate services provider","d":"A firm that incorporates and administers companies for clients, supplying registered offices, directors, shareholders and company secretarial services.","u":"/reference/glossary/corporate-services-provider/","k":"Glossary","x":"TCSP trust and company service provider"},{"t":"Designation","d":"The formal act of adding a person, entity, vessel or aircraft to a sanctions list, which triggers the restrictions attached to that programme.","u":"/reference/glossary/designation/","k":"Glossary","x":"listing"},{"t":"Common High Priority List","d":"A list of Harmonised System codes covering items assessed as most critical to a restricted military programme, published jointly by export control authorities.","u":"/reference/glossary/common-high-priority-list/","k":"Glossary","x":"CHPL common high priority items list"},{"t":"Designations feed","d":"A rolling, machine-readable record of additions to and removals from sanctions lists, published by the issuing authority and republished by aggregators.","u":"/reference/glossary/designations-feed/","k":"Glossary","x":""},{"t":"Deemed export","d":"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.","u":"/reference/glossary/deemed-export/","k":"Glossary","x":""},{"t":"Dual-use goods","d":"Items with legitimate civil applications that can also contribute to military or weapons programmes, and which are therefore export-controlled.","u":"/reference/glossary/dual-use-goods/","k":"Glossary","x":"dual-use items"},{"t":"End-user certificate","d":"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.","u":"/reference/glossary/end-user-certificate/","k":"Glossary","x":"EUC end-use statement"},{"t":"Entity List","d":"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.","u":"/reference/glossary/entity-list/","k":"Glossary","x":""},{"t":"Export control","d":"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.","u":"/reference/glossary/export-control/","k":"Glossary","x":""},{"t":"Enhanced due diligence","d":"Additional scrutiny applied where risk is assessed as higher, including deeper enquiry into source of funds, ownership and the purpose of specific transactions.","u":"/reference/glossary/enhanced-due-diligence/","k":"Glossary","x":"EDD"},{"t":"Flag of convenience","d":"Registration of a ship in a state with which its owners have no genuine connection, chosen for cost, tax or regulatory reasons.","u":"/reference/glossary/flag-of-convenience/","k":"Glossary","x":"FOC"},{"t":"Flag state","d":"The country in which a ship is registered, whose law governs the vessel and which is responsible for inspecting and certifying it.","u":"/reference/glossary/flag-state/","k":"Glossary","x":""},{"t":"Financial intelligence unit","d":"The national agency that receives suspicious activity reports, analyses them, and disseminates intelligence to law enforcement and to counterpart units abroad.","u":"/reference/glossary/financial-intelligence-unit/","k":"Glossary","x":"FIU"},{"t":"Facilitation","d":"Approving, financing, guaranteeing, brokering or otherwise assisting a transaction by a foreign person that the assisting party could not lawfully perform itself.","u":"/reference/glossary/facilitation/","k":"Glossary","x":""},{"t":"The 50 percent rule","d":"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.","u":"/reference/glossary/fifty-percent-rule/","k":"Glossary","x":"50% rule the fifty per cent rule"},{"t":"Free trade zone","d":"A designated area where goods may be landed, stored, handled and re-exported without the customs formalities that would apply in the domestic territory.","u":"/reference/glossary/free-trade-zone/","k":"Glossary","x":"FTZ free zone bonded warehouse"},{"t":"Foreign direct product rule","d":"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.","u":"/reference/glossary/foreign-direct-product-rule/","k":"Glossary","x":"FDPR"},{"t":"Front company","d":"A company that carries on some real business but exists substantially to conceal the involvement of another party in its transactions.","u":"/reference/glossary/front-company/","k":"Glossary","x":""},{"t":"Freight forwarder","d":"An intermediary that arranges carriage on behalf of shippers, books space, prepares documentation and may consolidate cargo from several customers.","u":"/reference/glossary/freight-forwarder/","k":"Glossary","x":""},{"t":"HS code","d":"A six-digit commodity code from the World Customs Organization Harmonised System, extended nationally, that determines the tariff and the controls applied to goods.","u":"/reference/glossary/hs-code/","k":"Glossary","x":"Harmonised System code tariff code commodity code"},{"t":"Incoterms","d":"Standard trade terms published by the International Chamber of Commerce that allocate cost, risk and responsibility for delivery between buyer and seller.","u":"/reference/glossary/incoterms/","k":"Glossary","x":""},{"t":"Hawala","d":"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.","u":"/reference/glossary/hawala/","k":"Glossary","x":"hundi informal value transfer"},{"t":"IMO number","d":"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.","u":"/reference/glossary/imo-number/","k":"Glossary","x":""},{"t":"Informal value transfer system","d":"Any arrangement that transfers value between parties without moving funds through the regulated banking system, settling obligations by netting or in kind.","u":"/reference/glossary/informal-value-transfer-system/","k":"Glossary","x":"IVTS"},{"t":"Fuzzy matching","d":"Name-matching that tolerates spelling, transliteration and word-order variation, scoring similarity rather than requiring an exact match.","u":"/reference/glossary/fuzzy-matching/","k":"Glossary","x":""},{"t":"General licence","d":"A published authorisation permitting a defined category of otherwise prohibited transactions, available to anyone who meets its terms without applying.","u":"/reference/glossary/general-licence/","k":"Glossary","x":"GL"},{"t":"Know your customer","d":"The obligation on a regulated firm to identify its customer, verify that identity, and understand the purpose of the relationship before providing services.","u":"/reference/glossary/know-your-customer/","k":"Glossary","x":"KYC"},{"t":"Layering","d":"Inserting successive intermediate parties, transactions or jurisdictions between an asset and its owner so that the connection cannot be established from any single record.","u":"/reference/glossary/layering/","k":"Glossary","x":""},{"t":"Letter of credit","d":"A bank undertaking to pay a seller against presentation of specified documents, substituting the bank's credit for the buyer's.","u":"/reference/glossary/letter-of-credit/","k":"Glossary","x":"documentary credit LC"},{"t":"Mirror statistics","d":"Comparing what one country reports exporting to a partner with what the partner reports importing from it, treating persistent gaps as evidence of misreporting.","u":"/reference/glossary/mirror-statistics/","k":"Glossary","x":"mirror trade analysis partner-country data comparison"},{"t":"Nominee director","d":"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.","u":"/reference/glossary/nominee-director/","k":"Glossary","x":"nominee shareholder straw director"},{"t":"Open registry","d":"A ship registry that accepts vessels owned by foreign nationals without requiring a national ownership or crewing link.","u":"/reference/glossary/open-registry/","k":"Glossary","x":""},{"t":"Over-invoicing","d":"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.","u":"/reference/glossary/over-invoicing/","k":"Glossary","x":""},{"t":"Phantom shipment","d":"A trade transaction documented and paid for in full where no goods, or substantially fewer goods, were ever shipped.","u":"/reference/glossary/phantom-shipment/","k":"Glossary","x":"fictitious trade ghost shipment"},{"t":"Mixer","d":"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.","u":"/reference/glossary/mixer/","k":"Glossary","x":"tumbler mixing service"},{"t":"Nested account","d":"The use of a bank's correspondent account by that bank's own respondent institutions, giving unnamed third banks indirect access to the correspondent.","u":"/reference/glossary/nested-account/","k":"Glossary","x":"downstream correspondent clearing"},{"t":"Panel of Experts","d":"A group of specialists appointed by the UN Security Council to monitor a sanctions regime and report publicly on violations and evasion methods.","u":"/reference/glossary/panel-of-experts/","k":"Glossary","x":"UN Panel of Experts PoE"},{"t":"Price cap","d":"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.","u":"/reference/glossary/price-cap/","k":"Glossary","x":""},{"t":"Professional enabler","d":"A lawyer, accountant, formation agent, broker or similar professional whose services are essential to concealing ownership or moving restricted value.","u":"/reference/glossary/professional-enabler/","k":"Glossary","x":""},{"t":"Protection and indemnity club","d":"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.","u":"/reference/glossary/protection-and-indemnity-club/","k":"Glossary","x":"P&I club P and I"},{"t":"Re-export","d":"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.","u":"/reference/glossary/re-export/","k":"Glossary","x":""},{"t":"Proliferation financing","d":"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.","u":"/reference/glossary/proliferation-financing/","k":"Glossary","x":"PF"},{"t":"Red-flag indicator","d":"A published, attributable observation that a transaction or relationship warrants further enquiry, drawn from patterns seen in past cases.","u":"/reference/glossary/red-flag-indicator/","k":"Glossary","x":"red flag risk indicator"},{"t":"Respondent bank","d":"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.","u":"/reference/glossary/respondent-bank/","k":"Glossary","x":""},{"t":"Sanctions","d":"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.","u":"/reference/glossary/sanctions/","k":"Glossary","x":""},{"t":"Screening","d":"Automated comparison of names, identifiers and other transaction data against sanctions lists and internal watchlists, at onboarding and on each payment.","u":"/reference/glossary/screening/","k":"Glossary","x":""},{"t":"Secondary sanctions","d":"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.","u":"/reference/glossary/secondary-sanctions/","k":"Glossary","x":""},{"t":"Specially Designated Nationals and Blocked Persons List","d":"The principal United States sanctions list. Property of anyone on it is blocked and US persons are generally prohibited from dealing with them.","u":"/reference/glossary/sdn-list/","k":"Glossary","x":"SDN List SDN"},{"t":"Secrecy jurisdiction","d":"A jurisdiction whose company, banking or trust law limits the information available about ownership and control to foreign authorities and counterparties.","u":"/reference/glossary/secrecy-jurisdiction/","k":"Glossary","x":"offshore financial centre"},{"t":"Sectoral sanctions","d":"Restrictions on particular types of dealing with named entities in a defined economic sector, rather than a full block on all dealings with them.","u":"/reference/glossary/sectoral-sanctions/","k":"Glossary","x":""},{"t":"Shadow fleet","d":"A loosely defined group of ageing tankers with opaque ownership and insurance that carry sanctioned or price-capped cargo outside mainstream shipping arrangements.","u":"/reference/glossary/shadow-fleet/","k":"Glossary","x":"dark fleet parallel fleet"},{"t":"Shell company","d":"A registered company with no significant operations, assets or employees, used to hold assets or to sit in a chain of ownership.","u":"/reference/glossary/shell-company/","k":"Glossary","x":""},{"t":"Ship-to-ship transfer","d":"Transferring cargo directly between two vessels at sea or at anchorage rather than through a port terminal.","u":"/reference/glossary/ship-to-ship-transfer/","k":"Glossary","x":"STS transfer lightering"},{"t":"Specific licence","d":"A written authorisation issued to a named applicant permitting a particular transaction that would otherwise be prohibited.","u":"/reference/glossary/specific-licence/","k":"Glossary","x":""},{"t":"Stablecoin","d":"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.","u":"/reference/glossary/stablecoin/","k":"Glossary","x":""},{"t":"Suspicious activity report","d":"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.","u":"/reference/glossary/suspicious-activity-report/","k":"Glossary","x":"SAR STR suspicious transaction report"},{"t":"Trade-based money laundering","d":"Moving value by misrepresenting the price, quantity or quality of goods in international trade, so that the transfer appears as ordinary commerce.","u":"/reference/glossary/trade-based-money-laundering/","k":"Glossary","x":"TBML"},{"t":"SWIFT","d":"A member-owned cooperative operating the messaging network banks use to exchange standardised payment and securities instructions internationally.","u":"/reference/glossary/swift/","k":"Glossary","x":""},{"t":"Trade misinvoicing","d":"Deliberately misstating the price, quantity or description of goods on trade documents so that the value recorded differs from the value actually exchanged.","u":"/reference/glossary/trade-misinvoicing/","k":"Glossary","x":"misinvoicing"},{"t":"Transshipment","d":"Unloading goods from one conveyance and reloading them onto another en route, so that the shipment reaches its destination through an intermediate country.","u":"/reference/glossary/transshipment/","k":"Glossary","x":""},{"t":"Typology","d":"A published study describing how a category of illicit activity is actually carried out, built from case material contributed by member jurisdictions.","u":"/reference/glossary/typology/","k":"Glossary","x":""},{"t":"Under-invoicing","d":"Stating a price below the true value of goods, so that value is retained abroad or duty and export restrictions are reduced.","u":"/reference/glossary/under-invoicing/","k":"Glossary","x":""},{"t":"Virtual asset service provider","d":"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.","u":"/reference/glossary/virtual-asset-service-provider/","k":"Glossary","x":"VASP"},{"t":"Wilful blindness","d":"Deliberately avoiding knowledge of a fact that would create liability, treated in enforcement practice as equivalent to knowing it.","u":"/reference/glossary/wilful-blindness/","k":"Glossary","x":"red flag knowledge deliberate ignorance"},{"t":"Wire stripping","d":"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.","u":"/reference/glossary/wire-stripping/","k":"Glossary","x":"payment stripping message stripping"},{"t":"Zombie registry","d":"A ship registry that continues to issue documentation in a state's name after that state has withdrawn authorisation, or that never had it.","u":"/reference/glossary/zombie-registry/","k":"Glossary","x":"false flag fraudulent registry"},{"t":"Omnibus account","d":"A single account in which a custodian or broker holds securities for many underlying clients together, in its own name, rather than in a separate named account for each.","u":"/reference/glossary/omnibus-account/","k":"Glossary","x":"nominee account street name account"},{"t":"Back-to-back letter of credit","d":"Two linked letters of credit for the same goods, one on each side of an intermediary, so the buyer's and the supplier's credits are separate instruments.","u":"/reference/glossary/back-to-back-letter-of-credit/","k":"Glossary","x":"back-to-back credit"},{"t":"Egregious case","d":"OFAC's label for a particularly serious violation calling for a strong enforcement response, which sets a much higher starting penalty than a non-egregious case.","u":"/reference/glossary/egregious-case/","k":"Glossary","x":"egregious violation"},{"t":"Strict liability","d":"Civil liability that does not depend on knowing or having reason to know a transaction was prohibited. OFAC applies it, and the UK's OFSI has since 15 June 2022.","u":"/reference/glossary/strict-liability/","k":"Glossary","x":"strict civil liability"},{"t":"Tolling agreement","d":"An agreement by a party under investigation to extend or suspend the statute of limitations, giving the regulator more time to finish before a deadline would otherwise bar action.","u":"/reference/glossary/tolling-agreement/","k":"Glossary","x":"statute of limitations tolling agreement"},{"t":"US-owned or controlled foreign entity","d":"A company organised outside the United States but owned or controlled by US persons, which some sanctions programmes treat as bound by the same prohibitions as a US person.","u":"/reference/glossary/us-owned-or-controlled-foreign-entity/","k":"Glossary","x":"foreign subsidiary of a US person"},{"t":"Voluntary self-disclosure","d":"A self-initiated notification to OFAC of an apparent violation, made before or at the same time as OFAC or another authority discovers it, which lowers the base penalty.","u":"/reference/glossary/voluntary-self-disclosure/","k":"Glossary","x":"VSD"},{"t":"Armenia","d":"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.","u":"/reference/jurisdictions/am/","k":"Jurisdiction"},{"t":"Georgia","d":"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.","u":"/reference/jurisdictions/ge/","k":"Jurisdiction"},{"t":"Cyprus","d":"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.","u":"/reference/jurisdictions/cy/","k":"Jurisdiction"},{"t":"Kyrgyzstan","d":"A Eurasian Economic Union member whose onward machinery exports to Russia rose roughly thirtyfold between 2021 and 2023, alongside a roughly ninefold rise in German and US shipments into the country over the same period.","u":"/reference/jurisdictions/kg/","k":"Jurisdiction"},{"t":"Kazakhstan","d":"A customs union member with extensive land connections to Russia and China, prominent in trade-statistics analysis of re-routed goods since 2022.","u":"/reference/jurisdictions/kz/","k":"Jurisdiction"},{"t":"Panama","d":"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.","u":"/reference/jurisdictions/pa/","k":"Jurisdiction"},{"t":"United Arab Emirates","d":"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.","u":"/reference/jurisdictions/ae/","k":"Jurisdiction"},{"t":"Hong Kong","d":"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.","u":"/reference/jurisdictions/hk/","k":"Jurisdiction"},{"t":"Türkiye","d":"A large manufacturing and transit economy whose trade with several restricted destinations has grown substantially, making it central to third-country routing analysis.","u":"/reference/jurisdictions/tr/","k":"Jurisdiction"},{"t":"Singapore","d":"A major trade financing, commodity trading and shipping centre whose intermediaries appear in enforcement records for the same volume reasons as other large hubs.","u":"/reference/jurisdictions/sg/","k":"Jurisdiction"},{"t":"China","d":"A very large manufacturing exporter, named as a transshipment point in US export-control alerts on Russia and described in Multilateral Sanctions Monitoring Team reporting as the place North Korea's stolen cryptocurrency is cashed out.","u":"/reference/jurisdictions/cn/","k":"Jurisdiction"},{"t":"Switzerland","d":"A major private banking and securities custody centre whose institutions appear in enforcement records for the same reason as other large financial hubs: they sit between clients and the US financial system.","u":"/reference/jurisdictions/ch/","k":"Jurisdiction"},{"t":"Germany","d":"A major European manufacturing and trading economy whose companies appear in enforcement records and investigations concerning exports that continued to Russia after 2022, alongside the country's own active enforcement effort.","u":"/reference/jurisdictions/de/","k":"Jurisdiction"},{"t":"Netherlands","d":"A major European trading and logistics hub whose port and trading companies appear in enforcement records the way any high-volume gateway does, from a criminal prosecution to an investigation still at the arrest stage.","u":"/reference/jurisdictions/nl/","k":"Jurisdiction"},{"t":"North Korea sanctions","d":"The most comprehensive UN-mandated regime, prohibiting most trade with North Korea, backed by Panel of Experts reporting that documents evasion in unusual detail.","u":"/reference/programs/dprk/","k":"Programme","x":"Democratic People's Republic of Korea"},{"t":"Russia sanctions","d":"Measures imposed from 2014 and greatly expanded from 2022, combining designations, sectoral restrictions, export controls and a price cap on seaborne oil.","u":"/reference/programs/russia/","k":"Programme","x":"Russian Federation"},{"t":"Syria sanctions","d":"US, EU and UK measures restricting dealings with the Syrian government, its energy sector and designated parties, with substantial humanitarian carve-outs.","u":"/reference/programs/syria/","k":"Programme","x":"Syrian Arab Republic"},{"t":"Iran sanctions","d":"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.","u":"/reference/programs/iran/","k":"Programme","x":"Islamic Republic of Iran"},{"t":"Belarus sanctions","d":"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.","u":"/reference/programs/belarus/","k":"Programme","x":"Republic of Belarus"},{"t":"Venezuela sanctions","d":"US measures targeting the Venezuelan government, the state oil company and designated individuals, with restrictions on debt, equity and petroleum dealings.","u":"/reference/programs/venezuela/","k":"Programme","x":"Bolivarian Republic of Venezuela"},{"t":"Cuba sanctions","d":"The oldest US embargo still administered by OFAC: the Cuban Assets Control Regulations of 1963, layered with later statutes, that prohibit most transactions involving Cuba or its nationals unless licensed.","u":"/reference/programs/cuba/","k":"Programme","x":"Cuba"},{"t":"Myanmar (Burma) sanctions","d":"The current US programme, built on E.O. 14014 of 2021, blocks the military, the defence and jet fuel sectors, and anyone materially supporting them. OFAC still uses the name Burma.","u":"/reference/programs/myanmar/","k":"Programme","x":"Myanmar (Burma)"},{"t":"Libya sanctions","d":"A UN regime aimed at armed groups, illicit petroleum exports and the misuse of Libyan state institutions, with a parallel US programme. The Panel of Experts' reporting documents fuel smuggling in unusual detail.","u":"/reference/programs/libya/","k":"Programme","x":"Libya"},{"t":"Yemen sanctions","d":"A UN travel ban, asset freeze and targeted arms embargo on designated individuals and entities, with a parallel US programme. Implementation of the asset freeze is, by the Panel's own account, limited.","u":"/reference/programs/yemen/","k":"Programme","x":"Yemen"},{"t":"Sudan sanctions","d":"A US embargo regime from 1997, revoked in 2017 and followed by targeted measures. Its main relevance here is historical: several of the largest penalties in OFAC's record concern conduct from the years it was in force.","u":"/reference/programs/sudan/","k":"Programme","x":"Sudan"},{"t":"BIS: the Bureau of Industry and Security","d":"The US Commerce Department bureau that administers export controls on dual-use items, maintains the Entity List, and enforces the Export Administration Regulations.","u":"/reference/authorities/bis/","k":"Authority","x":"BIS United States"},{"t":"DFAT: the Australian Department of Foreign Affairs and Trade","d":"The Australian department administering autonomous and UN sanctions, maintaining the Consolidated List and issuing permits.","u":"/reference/authorities/dfat/","k":"Authority","x":"DFAT Australia"},{"t":"Global Affairs Canada","d":"The Canadian department responsible for sanctions under the Special Economic Measures Act and related statutes, publishing consolidated lists and administering permits.","u":"/reference/authorities/gac/","k":"Authority","x":"GAC Canada"},{"t":"OFAC: the Office of Foreign Assets Control","d":"The US Treasury office that administers and enforces most US economic sanctions, publishes the SDN List, issues licences and imposes civil monetary penalties.","u":"/reference/authorities/ofac/","k":"Authority","x":"OFAC United States"},{"t":"EU sanctions: the Council, the Commission and member state authorities","d":"The EU adopts sanctions by Council decision and regulation; national competent authorities in each member state implement, licence and enforce them.","u":"/reference/authorities/eu/","k":"Authority","x":"EU European Union"},{"t":"SECO: the Swiss State Secretariat for Economic Affairs","d":"The Swiss authority implementing sanctions under the Embargo Act, maintaining the searchable sanctions list and administering exemptions.","u":"/reference/authorities/seco/","k":"Authority","x":"SECO Switzerland"},{"t":"UN sanctions: the Security Council and its committees","d":"The Security Council imposes sanctions by resolution; sanctions committees maintain the lists and Panels of Experts monitor and report on implementation.","u":"/reference/authorities/un/","k":"Authority","x":"UN International"},{"t":"OFSI: the Office of Financial Sanctions Implementation","d":"The UK Treasury office that implements financial sanctions, maintains the UK consolidated list, issues licences and imposes monetary penalties.","u":"/reference/authorities/ofsi/","k":"Authority","x":"OFSI United Kingdom"},{"t":"The Consolidated Screening List","d":"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.","u":"/reference/lists/consolidated-screening-list/","k":"List"},{"t":"The UK consolidated list","d":"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.","u":"/reference/lists/uk-sanctions-list/","k":"List"},{"t":"The BIS Entity List","d":"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.","u":"/reference/lists/entity-list/","k":"List"},{"t":"The UN Security Council Consolidated List","d":"The list of individuals and entities subject to measures imposed by the Security Council, maintained by its sanctions committees and implemented through national law.","u":"/reference/lists/un-consolidated-list/","k":"List"},{"t":"The EU consolidated list","d":"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.","u":"/reference/lists/eu-consolidated-list/","k":"List"},{"t":"The SDN List","d":"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.","u":"/reference/lists/sdn-list/","k":"List"},{"t":"Sanctions versus export controls","d":"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.","u":"/learn/sanctions-vs-export-controls/","k":"Learn","x":"What is the difference between sanctions and export controls?"},{"t":"How designations work","d":"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.","u":"/learn/how-designations-work/","k":"Learn","x":"How does someone get on a sanctions list?"},{"t":"Secondary sanctions","d":"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.","u":"/learn/secondary-sanctions/","k":"Learn","x":"What are secondary sanctions?"},{"t":"Who enforces sanctions","d":"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.","u":"/learn/who-enforces-sanctions/","k":"Learn","x":"Which agencies actually investigate and penalise sanctions violations?"},{"t":"How evasion is detected","d":"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.","u":"/learn/how-evasion-is-detected/","k":"Learn","x":"How do investigators actually find sanctions evasion?"},{"t":"What are sanctions?","d":"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.","u":"/learn/what-are-sanctions/","k":"Learn","x":"What are sanctions and how do they actually work?"},{"t":"The 50 percent rule","d":"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.","u":"/learn/the-50-percent-rule/","k":"Learn","x":"What is the 50 percent rule, and why is it different in the UK and EU?"},{"t":"General licences","d":"A general licence lets anyone meeting its conditions do something sanctions would otherwise prohibit, without applying. A specific licence is granted to one applicant for one transaction. General licences carry conditions, and breaching them is its own violation.","u":"/learn/general-licences/","k":"Learn","x":"What is a general licence versus a specific one?"},{"t":"How the oil price cap works","d":"The price cap lets service providers carry Russian oil only if it was bought at or below a set price. Because they cannot see the price, the US relies on recordkeeping, attestations and a safe harbour.","u":"/learn/price-cap/","k":"Learn","x":"How does the Russian oil price cap work?"},{"t":"Delisting","d":"Delisting is an administrative petition to the authority that listed you. In the US the regulations set out what to submit and promise a written decision; they do not promise a timeline or a meeting.","u":"/learn/delisting/","k":"Learn","x":"How does someone get removed from a sanctions list?"},{"t":"How penalties are decided","d":"Both OFAC and OFSI start from a base figure tied to the seriousness of the case, then reduce it for self-disclosure and cooperation and raise it for wilfulness. Reading the method explains why two similar breaches can end very differently.","u":"/learn/how-penalties-are-decided/","k":"Learn","x":"How are sanctions penalties calculated?"},{"t":"How US sanctions reach companies outside the United States","d":"A company with no US office can still be liable if a payment clears through a US bank, it is owned by a US person, or it handles US-origin goods. These are direct violations, not secondary sanctions.","u":"/learn/how-us-sanctions-reach-non-us-companies/","k":"Learn","x":"How do US sanctions reach companies outside the United States?"},{"t":"Where machinery exports to Russia went after 2022","d":"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.","u":"/blog/machinery-exports-after-2022/","k":"Note"},{"t":"How we compute mirror statistics, and what they cannot tell you","d":"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.","u":"/blog/mirror-statistics-method/","k":"Note"},{"t":"What the published OFAC penalty record actually looks like","d":"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.","u":"/blog/what-283-penalties-look-like/","k":"Note"},{"t":"What the US Consolidated Screening List contains","d":"The US screening list bundles 26,146 entries from twelve lists across three agencies. The OFAC SDN list is 74% of it; the Commerce Entity List has about as many Russian entries as Chinese ones.","u":"/blog/consolidated-screening-list-contents/","k":"Note"},{"t":"What OFSI's 21 published enforcement actions look like","d":"Eighteen monetary penalties worth about £28.1m and three disclosures without one. Banks are six of the 21 actions and 91% of the money. The median penalty is about £150,000, and most actions come from 2025 and 2026.","u":"/blog/what-21-ofsi-penalties-look-like/","k":"Note"},{"t":"The notice, read closely: FTI Consulting and six unpaid invoices","d":"OFAC's June 2026 release on FTI Consulting is about a payment structure built to avoid dealing with a sanctioned bank, and how the invoices still counted. The settlement was twice the base penalty, which the release explains.","u":"/blog/notice-read-closely-fti-consulting/","k":"Note"},{"t":"The notice, read closely: IPI Partners' missing facts","d":"OFAC's December 2025 release on IPI Partners is about a compliance team that asked the right question after a designation and got the wrong answer, because it never told its own lawyers what it knew.","u":"/blog/notice-read-closely-ipi-partners/","k":"Note"},{"t":"The bank settlements of 2009 to 2015, counted","d":"Nine bank settlements of $100 million or more, all between 2009 and 2015, make up 46 per cent of everything OFAC has published. In five of the six with a programme breakdown, the largest share was not Iran.","u":"/blog/bank-settlements-2009-2015/","k":"Note"},{"t":"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.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"A newly formed or recently reactivated trade entity suddenly engages in high-volume, high-value trade, in a sector with high barriers to entry.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"The corporate structure is unusually complex and illogical, involving shell companies or companies registered in high-risk jurisdictions.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"Shareholders or directors are formal nominees whose nominator is undisclosed, or informal nominees such as close associates and family.","d":"FATF, 2018","u":"/reference/red-flags/","k":"Indicator"},{"t":"Control over the assets is exercised through third parties — professional intermediaries, family members, associates or nominees — rather than through recorded ownership.","d":"FATF, 2018","u":"/reference/red-flags/","k":"Indicator"},{"t":"A jurisdiction permits companies to act as directors without restriction, so no natural person need appear in the filings at all.","d":"FATF, 2018","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"The entity shows unexplained periods of dormancy, or is not compliant with routine business obligations such as filing VAT returns.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"The entity maintains a minimal number of working staff, inconsistent with the volume of commodities it trades.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"Assets are distributed across multiple companies in multiple jurisdictions, so value passes through several layers of shell companies before reaching its destination.","d":"FATF, 2018","u":"/reference/red-flags/","k":"Indicator"},{"t":"The customer has little or no business background.","d":"BIS, 2025","u":"/reference/red-flags/","k":"Indicator"},{"t":"A foreign party to the transaction has one or more owners that are listed on the Entity List or the Military End User List.","d":"BIS, 2025","u":"/reference/red-flags/","k":"Indicator"},{"t":"A newly acquired foreign subsidiary continues operating its own transaction, export or customer-screening systems rather than being brought onto the parent's, with no date set for connecting the two.","d":"OFAC, 2019","u":"/reference/red-flags/","k":"Indicator"},{"t":"A foreign subsidiary or affiliate of a US company approves, signs off on, or otherwise facilitates a transaction with a sanctioned country, region or person, on the assumption that its non-US status puts it outside OFAC's reach.","d":"OFAC, 2019","u":"/reference/red-flags/","k":"Indicator"},{"t":"No post-acquisition audit or testing has been performed to check whether an acquired entity's transactions comply with sanctions rules, so any issues that predate or survive the deal remain undiscovered.","d":"OFAC, 2019","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"Trade documents describe the commodity only generically or non-specifically, in terms too vague to classify or value it.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"Commodities imported under a temporary importation or inward processing regime are subsequently exported with falsified documents.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"Shipments are routed through a number of jurisdictions without economic or commercial justification.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"Contracts supporting complex or regular trade are unusually simple, following a sample contract structure available on the internet.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"The product's capabilities do not fit the buyer's line of business — the example given is a small bakery ordering several sophisticated lasers.","d":"BIS, 2025","u":"/reference/red-flags/","k":"Indicator"},{"t":"The customer or purchasing agent is reluctant to offer information about the end use of a product.","d":"BIS, 2025","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"BIS, 2025","u":"/reference/red-flags/","k":"Indicator"},{"t":"Routine installation, training or maintenance services are declined by the customer.","d":"BIS, 2025","u":"/reference/red-flags/","k":"Indicator"},{"t":"A freight forwarding firm is listed as the product's final destination.","d":"BIS, 2025","u":"/reference/red-flags/","k":"Indicator"},{"t":"The customer is willing to pay cash for a very expensive item when the terms of sale call for financing.","d":"BIS, 2025","u":"/reference/red-flags/","k":"Indicator"},{"t":"Packaging is inconsistent with the stated method of shipment or the stated destination.","d":"BIS, 2025","u":"/reference/red-flags/","k":"Indicator"},{"t":"The buyer, when questioned, is evasive or unclear about whether the product is for domestic use, export or re-export.","d":"BIS, 2025","u":"/reference/red-flags/","k":"Indicator"},{"t":"The shipping route is abnormal for the product and the destination.","d":"BIS, 2025","u":"/reference/red-flags/","k":"Indicator"},{"t":"The customer is unfamiliar with the product's performance characteristics but still wants the product.","d":"BIS, 2025","u":"/reference/red-flags/","k":"Indicator"},{"t":"Delivery dates are vague, or deliveries are planned for out-of-the-way destinations.","d":"BIS, 2025","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"A trade entity consistently shows unreasonably low profit margins — importing wholesale commodities at or above retail value, or reselling at or below purchase price.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"The entity engages in complex trade deals involving numerous third-party intermediaries in incongruent lines of business.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"OFAC, 2020","u":"/reference/red-flags/","k":"Indicator"},{"t":"Transmitted AIS patterns or data are inconsistent with the ship's actual location.","d":"OFAC, 2023","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"OFAC, 2020","u":"/reference/red-flags/","k":"Indicator"},{"t":"A ship-to-ship transfer conceals the origin or destination of cargo rather than serving an operational purpose.","d":"OFAC, 2019","u":"/reference/red-flags/","k":"Indicator"},{"t":"A vessel repeatedly registers with new flag states — flag hopping — or falsifies its flag outright to mask illicit trade.","d":"OFAC, 2020","u":"/reference/red-flags/","k":"Indicator"},{"t":"A ship has undergone numerous administrative changes, such as repeated re-flagging.","d":"OFAC, 2023","u":"/reference/red-flags/","k":"Indicator"},{"t":"Vessel names and IMO numbers have been painted over with alternate ones so the ship can pass itself off as a different vessel.","d":"OFAC, 2018","u":"/reference/red-flags/","k":"Indicator"},{"t":"A vessel physically alters the identification it is required to display on its hull or superstructure.","d":"OFAC, 2018","u":"/reference/red-flags/","k":"Indicator"},{"t":"Shipping documentation for petrochemicals, petroleum, metals or sand has been falsified in order to disguise the cargo's origin.","d":"OFAC, 2020","u":"/reference/red-flags/","k":"Indicator"},{"t":"A ship relies on unknown, untested, sporadic or fraudulent insurance, without which it could not meet the costs of an accident or spill.","d":"OFAC, 2023","u":"/reference/red-flags/","k":"Indicator"},{"t":"An insurer's financial soundness, track record, regulatory record or ownership structure cannot be established on review.","d":"OFAC, 2023","u":"/reference/red-flags/","k":"Indicator"},{"t":"Shipping and ancillary costs such as freight, customs and insurance are inflated or bundled, concealing the price actually paid for the oil.","d":"OFAC, 2023","u":"/reference/red-flags/","k":"Indicator"},{"t":"A counterparty will not provide an itemised breakdown of all costs from which the price paid for the oil could be determined.","d":"OFAC, 2023","u":"/reference/red-flags/","k":"Indicator"},{"t":"Intermediary companies such as managers, traders or brokerages conceal their beneficial ownership or otherwise engage in unusually opaque practices.","d":"OFAC, 2023","u":"/reference/red-flags/","k":"Indicator"},{"t":"A vessel navigates suspicious deviations in route — changes with no legitimate reason to go off-route, such as unsafe ports, extreme weather or emergencies.","d":"OFAC, 2020","u":"/reference/red-flags/","k":"Indicator"},{"t":"Malign actors disguise the ultimate origin or destination of cargo by indirect routing, unscheduled detours, or transit through third countries.","d":"OFAC, 2020","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"OFAC, 2020","u":"/reference/red-flags/","k":"Indicator"},{"t":"AIS is disabled for periods inconsistent with the safety convention that requires it to be transmitted.","d":"OFAC, 2019","u":"/reference/red-flags/","k":"Indicator"},{"t":"A respondent provides correspondent banking services onward to other institutions — a downstream, or nested, arrangement — so the correspondent serves customers it never onboarded.","d":"Wolfsberg Group, 2022","u":"/reference/red-flags/","k":"Indicator"},{"t":"It cannot be determined whether the respondent has controls in place to ensure payment transparency in the services it offers onward.","d":"Wolfsberg Group, 2022","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"Incoming wire transfers to a trade-related account are split and forwarded to unrelated accounts with little or no connection to commercial activity.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"Payments are routed in a circle: funds sent from one country and received back in the same country after passing through others.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"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.","d":"FATF, 2013","u":"/reference/red-flags/","k":"Indicator"},{"t":"Settlement between operators is made through value or cash outside the banking system, including by cash couriers, rather than through traceable transfers.","d":"FATF, 2013","u":"/reference/red-flags/","k":"Indicator"},{"t":"An operator's settlement commingles licit and illicit proceeds and nets obligations across jurisdictions, masking the individual fund transfers.","d":"FATF, 2013","u":"/reference/red-flags/","k":"Indicator"},{"t":"The operator's business includes gold dealing alongside money transfer and currency exchange.","d":"FATF, 2013","u":"/reference/red-flags/","k":"Indicator"},{"t":"An account shows an unexpectedly high number or value of transactions inconsistent with the client's stated business activity.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"Cash deposits or other transactions are consistently just below the relevant reporting thresholds.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"Transaction activity associated with a trade entity increases quickly and significantly in volume, then goes dormant after a short period.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"A custodian holding a client's securities in an omnibus account does not screen the underlying account holders and beneficial owners against sanctions lists, relying only on the intermediary's own screening.","d":"ISSA, 2019","u":"/reference/red-flags/","k":"Indicator"},{"t":"The underlying beneficial owner of assets held through an omnibus or nominee securities account is not identified or disclosed to the custodian holding the account, or to the counterparties clearing through it.","d":"ISSA, 2019","u":"/reference/red-flags/","k":"Indicator"},{"t":"A securities intermediary does not periodically reassess whether maintaining an omnibus account for a particular account holder remains appropriate given its sanctions risk.","d":"ISSA, 2019","u":"/reference/red-flags/","k":"Indicator"},{"t":"A firm has never run a test simulating access or a transaction from a sanctioned jurisdiction to confirm its own screening or geo-blocking controls actually stop it.","d":"OFAC, 2019","u":"/reference/red-flags/","k":"Indicator"},{"t":"A screening or geo-blocking control was disabled for a software update, a migration or a vendor change, and nothing in the process required confirming it was switched back on.","d":"OFAC, 2026","u":"/reference/red-flags/","k":"Indicator"},{"t":"An automated tool built to test that screening or geo-blocking controls actually work is quietly discontinued, disabled, or blocked by the firm's own infrastructure, and never replaced.","d":"OFAC, 2026","u":"/reference/red-flags/","k":"Indicator"},{"t":"A firm holds internet protocol address information about its users but does not use it to screen for and prevent potential sanctions violations.","d":"OFAC, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"Geolocation tools and IP address blocking controls are not used to identify and prevent access from sanctioned jurisdictions.","d":"OFAC, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"Customer information obtained at onboarding and through the relationship is not used to conduct due diligence sufficient to mitigate sanctions risk.","d":"OFAC, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"Value moves through anonymity-enhanced cryptocurrencies, mixers and tumblers, decentralised platforms or privacy wallets that reduce transparency and increase obfuscation of financial flows.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"},{"t":"Products and services are used specifically because they enable or allow for reduced transparency and increased obfuscation of financial flows.","d":"FATF, 2021","u":"/reference/red-flags/","k":"Indicator"}]