Sanctions Evasion

Sanctions Evasion via Intermediaries

Use of intermediary entities, agents, or correspondent chains to circumvent sanctions on designated individuals, entities, or jurisdictions. Includes trade diversion, front companies, and complex payment routing.

Firm typesE-Money Institution (EMI)Payment Institution (PI)Bank / Credit InstitutionMoney Service Business (MSB)Neobank / Digital Bank

ProductsCross-Border PaymentsTrade FinanceFX TransfersRemittance

CustomersCorporatesSMEsAgents & Intermediaries

Key terms:TypologyTransaction monitoringSAREDDRed-flag indicator

What it is

Control objective

Detect potential sanctions evasion through intermediary structures, complex payment routing, and misuse of correspondent relationships to reach sanctioned parties or jurisdictions.

Data required

Full payment chain (originator through all intermediaries to beneficiary)
OFSI, OFAC, EU, and UN consolidated sanctions lists
Beneficiary institution and country
Trade documentation (invoices, shipping docs, bills of lading)
Intermediary entity details and beneficial ownership
Dual-use goods classifications
End-user certificates where applicable
Historical payment routing patterns

Related typologies (Sanctions Evasion)

Front Companies & Beneficial-Ownership Obfuscation

Layered shell or front companies and nominee directors used to conceal a sanctioned or designated person in control of an account or flow. Jurisdiction hopping and opaque ownership chains break the link between the visible customer and the true beneficial owner to evade sanctions screening.

Next steps

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