Sanctions Evasion Reference

Sources

Every dataset this site ingests and every document it cites, with publisher, licence, update cadence and last fetch date. The ingest table is generated from the scripts' own metadata files.

ingested datasets

4

cited documents

110

last ingest

2026-09-07

Ingested datasets

These are refetched by scripts in this site's repository, running locally on a schedule. The table below is generated from the _meta.json file each script writes, so the dates here are the real fetch dates. If a dataset stops updating, this page stops moving, which is the point of generating it this way rather than maintaining it by hand.

DatasetPublisher LicenceCadence RecordsLast fetched
comtrade-mirror UN Comtrade (public preview endpoint) UN Comtrade terms of use: free for non-commercial use with attribution monthly 144 2026-09-07
designations OFAC Recent Actions US federal government work, public domain (17 U.S.C. § 105) daily 91 2026-09-07
ofac-penalties OFAC Civil Penalties and Enforcement Information US federal government work, public domain (17 U.S.C. § 105) weekly 283 2026-09-07
sdn-stats OFAC Specially Designated Nationals and Blocked Persons List (SDN.XML) US federal government work, public domain (17 U.S.C. § 105) daily 6 2026-09-07

Licensing decisions we have had to make

OpenSanctions

OpenSanctions is free for non-commercial use and separately licensed for commercial use. We do not ingest OpenSanctions data. The decision was made deliberately early, to avoid relying on a non-commercial characterisation of a site that might not always be structured that way — and this site now carries advertising, which settles the question rather than raising it for the first time. Where cross-authority entity counts appear on this site they come from the authorities' own published files, which are government works.

UN Comtrade

Used through the public preview endpoint, which requires no key. Comtrade's terms permit free use for non-commercial purposes with attribution, which every chart drawn from it carries. Advertising on this site raised the same question that ruled out OpenSanctions, and this dataset was reviewed against it separately rather than treated as settled by that earlier decision. Comtrade's own description of the database is for use "by governments, academia, research institutes, and enterprises" — broader than a strict non-commercial reading — and the conclusion reached was that an ad-supported public reference publishing derived aggregates, not reselling or redistributing the underlying data, is not the use the non-commercial term is aimed at restricting. Only derived aggregates are published here; the bulk data is not redistributed.

US federal government works

OFAC, BIS, FinCEN and Department of Justice material is not subject to copyright in the United States under 17 U.S.C. § 105. We republish only derived statistics and links, not the lists themselves — anyone screening against sanctions must use the authority's own files.

Everything else

FATF, Egmont Group, UN Panel of Experts and OFSI documents are cited and linked, never reproduced. Where this site quotes a red-flag indicator it does so at the length necessary to state the indicator, with attribution to the publisher, and links to the source document.

This site's own text

Licensed CC BY 4.0. The glossary is additionally published as a machine-readable file so that the other sites in this set can use identical definitions.

Documents cited

Every document any page on this site cites, in one list. All 110 URLs are checked by npm run check before deploy, including a check for soft 404s where an agency silently redirects a retired document path to its homepage.

Official advisories and guidance

  1. Frequently Asked Questions. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.
  2. Alerts, Advisories, Notices, Bulletins and Fact Sheets. U.S. Financial Crimes Enforcement Network, 2026.
  3. Don't Let This Happen to You: Actual Investigations of Export Control and Antiboycott Violations. U.S. Bureau of Industry and Security, Office of Export Enforcement, 2024.
  4. Sanctions Advisory for the Maritime Oil Industry and Related Sectors. U.S. Department of the Treasury, Office of Foreign Assets Control, 2023. Price cap advisory, 12 October 2023.
  5. Sanctions Compliance Guidance for the Virtual Currency Industry. U.S. Department of the Treasury, Office of Foreign Assets Control, 2021.
  6. Guidance to Address Illicit Shipping and Sanctions Evasion Practices. U.S. Department of State, U.S. Department of the Treasury and U.S. Coast Guard, 2020. Global maritime advisory, 14 May 2020.
  7. Syria Shipping Advisory: Sanctions Risks Related to Petroleum Shipments to Syria. U.S. Department of the Treasury, Office of Foreign Assets Control, 2019.
  8. North Korea Vessel Advisory: Sanctions Risks Related to Shipping with North Korea. U.S. Department of the Treasury, Office of Foreign Assets Control, 2018.

Typology and standard-setting reports

  1. Egmont Group of Financial Intelligence Units. Egmont Group, 2026.
  2. Correspondent banking principles and guidance. The Wolfsberg Group, 2022.
  3. Wolfsberg Financial Crime Principles for Correspondent Banking. The Wolfsberg Group, 2022.
  4. Trade-Based Money Laundering: Risk Indicators. Financial Action Task Force and Egmont Group, 2021.
  5. Guidance on Proliferation Financing Risk Assessment and Mitigation. Financial Action Task Force, 2021.
  6. Updated Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers. Financial Action Task Force, 2021.
  7. Trade-Based Money Laundering: Trends and Developments. Financial Action Task Force and Egmont Group, 2020.
  8. Concealment of Beneficial Ownership. Financial Action Task Force and Egmont Group, 2018.
  9. Professional Money Laundering. Financial Action Task Force, 2018.
  10. The Role of Hawala and Other Similar Service Providers in Money Laundering and Terrorist Financing. Financial Action Task Force, 2013.

UN Panel of Experts reports

  1. Unlawful Military Cooperation including Arms Transfers between North Korea and Russia (MSMT/2025/1). Multilateral Sanctions Monitoring Team, 2025. First MSMT report, 29 May 2025; circulated to the Security Council as S/2025/340.
  2. The DPRK's Violation and Evasion of UN Sanctions through Cyber and Information Technology Worker Activities (MSMT/2025/2). Multilateral Sanctions Monitoring Team, 2025. Second MSMT report, 22 October 2025.
  3. Reports of the Panel of Experts, 1718 Committee (Democratic People's Republic of Korea). United Nations Security Council, 2024.
  4. Report of the Panel of Experts established pursuant to resolution 1874 (2009). United Nations Security Council, 2024. S/2024/215, the Panel's final report before its mandate lapsed.
  5. Midterm report of the Panel of Experts established pursuant to resolution 1874 (2009). United Nations Security Council, 2019. S/2019/691.
  6. Report of the Panel of Experts established pursuant to resolution 1874 (2009). United Nations Security Council, 2018. S/2018/171.

Regulations, lists and legal instruments

  1. Sanctions Programs and Country Information. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.
  2. Entity List, Supplement No. 4 to Part 744 of the Export Administration Regulations. U.S. Bureau of Industry and Security, 2026.
  3. Sanctions (restrictive measures). European Commission, Directorate-General for Financial Stability, 2026.
  4. Canadian sanctions. Global Affairs Canada, 2026.
  5. Australia and sanctions. Australian Department of Foreign Affairs and Trade, 2026.
  6. Sanctions and embargoes. Swiss State Secretariat for Economic Affairs (SECO), 2026.
  7. The FATF Recommendations. Financial Action Task Force, 2025.
  8. Red Flags, Supplement No. 3 to Part 732 of the Export Administration Regulations. U.S. Bureau of Industry and Security (via the electronic Code of Federal Regulations), 2025. The canonical BIS red-flag indicators of possible unlawful diversion.
  9. Common High Priority Items List (CHPL). U.S. Bureau of Industry and Security, with the European Union, Japan and the United Kingdom, 2024. Common High Priority Items List (CHPL), 23 February 2024.
  10. Financial sanctions enforcement and monetary penalties guidance. HM Treasury, Office of Financial Sanctions Implementation, 2024. Section 146 of the Policing and Crime Act 2017 as amended.
  11. Budget Implementation Act, 2022, No. 1, Part 5 Division 31. Government of Canada (Justice Laws Website), 2022. Forfeiture of property seized under the Special Economic Measures Act.
  12. Policing and Crime Act 2017, section 146. UK Parliament (legislation.gov.uk), 2017.
  13. Revised Guidance on Entities Owned by Persons Whose Property and Interests in Property Are Blocked. U.S. Department of the Treasury, Office of Foreign Assets Control, 2014. The 50 Percent Rule, 13 August 2014.

Penalty notices and enforcement releases

  1. Imposition of Monetary Penalty – Citibank, N.A., London Branch. HM Treasury, Office of Financial Sanctions Implementation, 2026. Public penalty notice, 11 August 2026.
  2. Civil Penalties and Enforcement Information. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.
  3. Financial sanctions enforcement: decisions and monetary penalties imposed. HM Treasury, Office of Financial Sanctions Implementation, 2026.
  4. Enforcement action: Adani Enterprises Limited. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026. Penalty notice, 2026-05-18, US$275,000,000.
  5. Enforcement action: GVA Capital Ltd.. U.S. Department of the Treasury, Office of Foreign Assets Control, 2025. Penalty notice, 2025-06-12, US$215,988,868.
  6. Enforcement action: Family International Realty LLC and an Individual. U.S. Department of the Treasury, Office of Foreign Assets Control, 2025. Penalty notice, 2025-01-16, US$1,076,923.
  7. Imposition of Monetary Penalty – Herbert Smith Freehills CIS LLP (HSF Moscow). HM Treasury, Office of Financial Sanctions Implementation, 2024. Public penalty notice, 11 November 2024.
  8. Enforcement action: SkyGeek Logistics, Inc.. U.S. Department of the Treasury, Office of Foreign Assets Control, 2024. Penalty notice, 2024-12-31, US$22,172.
  9. Enforcement action: Binance. U.S. Department of the Treasury, Office of Foreign Assets Control, 2023. Penalty notice, 2023-11-21, US$968,618,825.
  10. Enforcement action: British American Tobacco p.l.c.. U.S. Department of the Treasury, Office of Foreign Assets Control, 2023. Penalty notice, 2023-04-25, US$508,612,492.
  11. Enforcement action: Swedbank AS (Latvia). U.S. Department of the Treasury, Office of Foreign Assets Control, 2023. Penalty notice, 2023-06-20, US$3,430,900.
  12. Enforcement action: Bittrex, Inc.. U.S. Department of the Treasury, Office of Foreign Assets Control, 2022. Penalty notice, 2022-10-11, US$24,280,829.2.
  13. Enforcement action: Sojitz (Hong Kong) Limited. U.S. Department of the Treasury, Office of Foreign Assets Control, 2022. Penalty notice, 2022-01-11, US$5,228,298.
  14. Enforcement action: Toll Holdings Limited. U.S. Department of the Treasury, Office of Foreign Assets Control, 2022. Penalty notice, 2022-04-25, US$6,131,855.
  15. Enforcement action: Nordgas, S.r.l.. U.S. Department of the Treasury, Office of Foreign Assets Control, 2021. Penalty notice, 2021-03-26, US$950,000.
  16. Enforcement action: Essentra FZE Company Limited. U.S. Department of the Treasury, Office of Foreign Assets Control, 2020. Penalty notice, 2020-07-16, US$665,112.
  17. Enforcement action: Standard Chartered Bank. U.S. Department of the Treasury, Office of Foreign Assets Control, 2019. Penalty notice, 2019-04-09, US$657,040,033.
  18. Enforcement action: UniCredit Bank. U.S. Department of the Treasury, Office of Foreign Assets Control, 2019. Penalty notice, 2019-04-15, US$611,023,421.
  19. Enforcement action: MID-SHIP Group. U.S. Department of the Treasury, Office of Foreign Assets Control, 2019. Penalty notice, 2019-05-02, US$871,837.
  20. Enforcement action: Apollo Aviation Group, LLC. U.S. Department of the Treasury, Office of Foreign Assets Control, 2019. Penalty notice, 2019-11-07, US$210,600.
  21. Enforcement action: Epsilon Electronics, Inc.. U.S. Department of the Treasury, Office of Foreign Assets Control, 2018. Penalty notice, 2018-09-13, US$1,500,000.
  22. Enforcement action: Zhongxing Telecommunications Equipment Corporation. U.S. Department of the Treasury, Office of Foreign Assets Control, 2017. Penalty notice, 2017-03-07, US$100,871,266.
  23. Enforcement action: Commerzbank AG. U.S. Department of the Treasury, Office of Foreign Assets Control, 2015. Penalty notice, 2015-03-12, US$258,660,796.
  24. Enforcement action: BNP Paribas SA. U.S. Department of the Treasury, Office of Foreign Assets Control, 2014. Penalty notice, 2014-06-30, US$963,619,900.
  25. Enforcement action: Clearstream Banking, S.A.. U.S. Department of the Treasury, Office of Foreign Assets Control, 2014. Penalty notice, 2014-01-23, US$151,902,000.
  26. Enforcement action: Fokker Services B.V.. U.S. Department of the Treasury, Office of Foreign Assets Control, 2014. Penalty notice, 2014-06-05, US$50,922,208.
  27. Enforcement action: ING Bank N.V.. U.S. Department of the Treasury, Office of Foreign Assets Control, 2012. Penalty notice, 2012-06-12, US$619,000,000.
  28. Enforcement action: Credit Suisse AG. U.S. Department of the Treasury, Office of Foreign Assets Control, 2009. Penalty notice, 2009-12-16, US$536,000,000.

Court records

  1. CourtListener and the RECAP Archive. Free Law Project, 2026.
  2. United States v. Flighttime Enterprises, Inc., 1:25-cr-00017 (S.D. Ohio) — docket. CourtListener / RECAP Archive, Free Law Project, 2025. Docket 1:25-cr-00017, filed 12 Feb 2025.
  3. Ohio-Based Supplier of Aircraft Parts and Three Employees Charged for Illicit Export Scheme Involving Russia. U.S. Department of Justice, Office of Public Affairs, 2025. Indictment announced 13 February 2025.
  4. United States v. Sinyavsky, 1:24-cr-20529 (S.D. Fla.) — docket. CourtListener / RECAP Archive, Free Law Project, 2024. Docket 1:24-cr-20529, filed 4 Dec 2024, guilty plea 16 Jan 2025 — the same day as this case's OFAC settlement. Docket text references Family International Realty, Abramov and Perevalov by name..
  5. Brooklyn Resident and Two Russian-Canadian Nationals Charged with Massive Sanctions Evasion and Export Control Scheme. U.S. Attorney’s Office, Eastern District of New York, 2023.
  6. Turkish Bank Charged In Manhattan Federal Court For Its Participation In A Multibillion-Dollar Iranian Sanctions Evasion Scheme. U.S. Attorney’s Office, Southern District of New York, 2019. Indictment, October 2019.
  7. Turkish Banker Convicted Of Conspiring To Evade U.S. Sanctions Against Iran And Other Offenses. U.S. Attorney’s Office, Southern District of New York, 2018. Verdict, 3 January 2018.
  8. Turkish Banker Mehmet Hakan Atilla Sentenced To 32 Months For Conspiring To Violate U.S. Sanctions Against Iran And Other Offenses. U.S. Attorney’s Office, Southern District of New York, 2018.
  9. United States v. ZTE Corporation, 3:17-cr-00120 (N.D. Tex.) — docket. CourtListener / RECAP Archive, Free Law Project, 2017. Docket 3:17-cr-00120, filed 7 Mar 2017.
  10. United States v. Zarrab, 1:15-cr-00867 (S.D.N.Y.) — docket. CourtListener / RECAP Archive, Free Law Project, 2015. Docket 1:15-cr-00867, filed 15 Dec 2015. Halkbank was added by superseding indictment in this same docket in 2019, not a separate case number..
  11. United States v. Commerzbank AG, 1:15-cr-00031 (D.D.C.) — docket. CourtListener / RECAP Archive, Free Law Project, 2015. Docket 1:15-cr-00031, filed 12 Mar 2015.
  12. Epsilon Electronics, Inc. v. U.S. Department of the Treasury, OFAC, 1:14-cv-02220 (D.D.C.) — docket. CourtListener / RECAP Archive, Free Law Project, 2014. Docket 1:14-cv-02220, filed 31 Dec 2014, terminated 7 Mar 2016 (appealed thereafter to the D.C. Circuit).
  13. United States v. BNP Paribas S.A., 1:14-cr-00460 (S.D.N.Y.) — docket. CourtListener / RECAP Archive, Free Law Project, 2014. Docket 1:14-cr-00460, filed 9 Jul 2014.
  14. United States v. Fokker Services B.V., 1:14-cr-00121 (D.D.C.) — docket. CourtListener / RECAP Archive, Free Law Project, 2014. Docket 1:14-cr-00121, filed 4 Jun 2014.

Official press releases

  1. Export Enforcement. U.S. Bureau of Industry and Security, 2026.
  2. Office of Public Affairs press releases. U.S. Department of Justice, 2026.
  3. Treasury Disrupts Iranian Regime's Strait of Hormuz Extortion Network. U.S. Department of the Treasury, 2026. Press release sb0581, 29 July 2026.
  4. Treasury Exposes Money Laundering Network Using Digital Assets to Evade Sanctions. U.S. Department of the Treasury, 2024. Press release jy2735, 4 December 2024.
  5. Treasury Sanctions Entities for Transporting Oil Sold Above the Coalition Price Cap. U.S. Department of the Treasury, 2023. Press release jy1795, 12 October 2023.
  6. Treasury Sanctions Mixer Used by the DPRK to Launder Stolen Virtual Currency. U.S. Department of the Treasury, 2023. Press release jy1933, 29 November 2023.
  7. U.S. Treasury Issues First-Ever Sanctions on a Virtual Currency Mixer, Targets DPRK Cyber Threats. U.S. Department of the Treasury, 2022. Press release jy0768, 6 May 2022.
  8. U.S. Treasury Sanctions Notorious Virtual Currency Mixer Tornado Cash. U.S. Department of the Treasury, 2022. Press release jy0916, 8 August 2022.
  9. Canada starts first process to seize and pursue the forfeiture of assets of sanctioned Russian oligarch. Global Affairs Canada, 2022.
  10. Treasury Designates Iran-Based Financial Facilitators of Malicious Cyber Activity and for the First Time Identifies Associated Digital Currency Addresses. U.S. Department of the Treasury, 2018. Press release sm556, 28 November 2018.

Datasets and data services

  1. Recent Actions. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.
  2. Specially Designated Nationals and Blocked Persons List (SDN.XML). OFAC Sanctions List Service, 2026.
  3. United Nations Security Council Consolidated List. United Nations Security Council, 2026.
  4. Consolidated Screening List. U.S. International Trade Administration, 2026.
  5. Consolidated Screening List Search. U.S. International Trade Administration, 2026.
  6. Financial sanctions: consolidated list of targets. HM Treasury, Office of Financial Sanctions Implementation, 2026.
  7. EU Sanctions Map. European Union, 2026.
  8. Consolidated list of persons, groups and entities subject to EU financial sanctions. European Commission, 2026.
  9. UN Comtrade Database. United Nations Statistics Division, 2026.
  10. International trade in goods database. Eurostat, 2026.
  11. USA Trade Online. U.S. Census Bureau, 2026.
  12. Data licensing. OpenSanctions, 2026.
  13. OpenCorporates. OpenCorporates, 2026.
  14. Offshore Leaks Database. International Consortium of Investigative Journalists, 2026.
  15. Companies House Developer Hub. UK Companies House, 2026.

Research and NGO publications

  1. Open Ownership. Open Ownership, 2026.
  2. Conflict Armament Research field investigations. Conflict Armament Research, 2026.
  3. Centre for Research on Energy and Clean Air. CREA, 2026.
  4. KSE Institute sanctions analytics. Kyiv School of Economics Institute, 2026.
  5. Trade Misinvoicing. Global Financial Integrity, 2024.
  6. Crypto Crime Report. Chainalysis, 2024.