International Trade AlertKey Points
On March 31, 2026, OFAC published a Sanctions Advisory that highlights compliance risks arising from sham transactions used to evade sanctions.
The Sanctions Advisory highlights certain kinds of opaque legal structures, including trusts, that may be used to conceal a blocked person’s continuing interest in property.
The Sanctions Advisory builds on OFAC’s prior guidance by providing a non-exhaustive list of red flags that may be indicative of a sham transacti...
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