Start here
Five reading paths through the site, each ordered from the basics to a documented enforcement case, for readers arriving from the news, from compliance work, trade, banking or research.
- paths
-
5
- search
The site has more than two hundred pages and no obvious front door for every reader. Pick the line that sounds like you. Each path runs in order, and every step links onward to the rest.
You read a headline and want to know what it means
The shortest route from "a company was fined for sanctions violations" to understanding what actually happened.
- What are sanctions and how do they actually work? 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.
- Which agencies actually investigate and penalise sanctions violations? 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.
- How do investigators actually find sanctions evasion? 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.
- What is a front company? 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.
- ZTE: front companies and an internal plan to keep supplying Iran 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.
You are new to sanctions compliance
How lists, ownership rules and screening fail in practice, using penalty notices in which the regulator says exactly where.
- How does someone get on a sanctions list? 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.
- What is the 50 percent rule, and why is it different in the UK and EU? 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.
- What is a general licence versus a specific one? 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.
- What is ownership threshold structuring? 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.
- Deutsche Bank London: a screening list with no ownership data 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.
- Citibank London: 970 payments, one missed prefix 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.
You want to understand trade and shipping
What the paperwork says a shipment is against what it is, and how oil moves outside the price cap.
- How does the Russian oil price cap work? 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.
- What is trade misinvoicing? 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.
- What is HS code misclassification? 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.
- What is third-country transshipment? Routing restricted goods through an intermediate country so that the shipment reaching the restricted destination appears to originate somewhere the exporter would have supplied without question.
- What is a ship-to-ship transfer? 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.
- Adani Enterprises: 35 cargoes of LPG that were not Omani 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.
You want to understand banking and payments
How payments reach a currency they could not access directly, and where banks are found to have missed it.
- How is correspondent banking used to evade sanctions? Using a chain of banks that each know only their own customer, so that a payment for a restricted party reaches a currency it could not access directly, without any bank in the chain seeing the whole transaction.
- Nested account The use of a bank's correspondent account by that bank's own respondent institutions, giving unnamed third banks indirect access to the correspondent.
- What are third-country bank accounts and how are they used? 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.
- BNP Paribas: the $963m correspondent banking settlement 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.
- How is cryptocurrency used to evade sanctions? 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.
- Binance: a matching engine with no jurisdiction in it 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.
You are a researcher who wants the data
The datasets behind the site, published as spreadsheets and feeds, with the notes on how each was built.