diff --git a/Dockerfile b/Dockerfile index 1963a67..e13abcc 100644 --- a/Dockerfile +++ b/Dockerfile @@ -34,6 +34,9 @@ COPY scenarios/ ./scenarios/ COPY glossary/ ./glossary/ # Round 21 pSEO — OFAC sanctions programs index COPY programs/ ./programs/ +# Round 48 pSEO — sanctions evasion typologies and jurisdiction risk ratings +COPY evasion/ ./evasion/ +COPY risk-ratings/ ./risk-ratings/ # Interactive shareable tools (compliance-check, ai-spend-optimizer) COPY tools/ ./tools/ # R17 UX system — shared design system across portfolio diff --git a/api.py b/api.py index e5c7eb5..da314de 100644 --- a/api.py +++ b/api.py @@ -3597,7 +3597,7 @@ def do_GET(self): if _os.path.isfile(_rp): with open(_rp, "r", encoding="utf-8") as _fh: return self._serve_text(_fh.read(), "text/html; charset=utf-8") - for _pfx in ("/vs/", "/faq/", "/learn/", "/alternatives-to/", "/penalties/", "/guides/", "/checklists/", "/cost-of/", "/best/", "/templates/", "/stats/", "/redflags/", "/scenarios/", "/programs/", "/benchmarks/"): + for _pfx in ("/vs/", "/faq/", "/learn/", "/alternatives-to/", "/penalties/", "/guides/", "/checklists/", "/cost-of/", "/best/", "/templates/", "/stats/", "/redflags/", "/scenarios/", "/programs/", "/benchmarks/", "/evasion/", "/risk-ratings/"): if p.path.startswith(_pfx): _slug = p.path[len(_pfx):].split("?")[0].split("/")[0] if not _slug: @@ -6470,6 +6470,43 @@ def _sitemap_xml(self): ("/glossary/ofac-web3-regulation-glossary-3", "monthly", "0.7", "Ofac Web3 Regulation Glossary 3"), ("/glossary/ofac-web3-regulation-glossary-4", "monthly", "0.7", "Ofac Web3 Regulation Glossary 4"), ("/glossary/ofac-web3-regulation-glossary-5", "monthly", "0.7", "Ofac Web3 Regulation Glossary 5"), + ("/evasion/cross-chain-bridge-evasion", "monthly", "0.8", "Cross Chain Bridge Evasion"), + ("/evasion/shell-company-front-companies", "monthly", "0.8", "Shell Company Front Companies"), + ("/evasion/trade-based-money-laundering", "monthly", "0.8", "Trade Based Money Laundering"), + ("/evasion/crypto-mixer-evasion", "monthly", "0.8", "Crypto Mixer Evasion"), + ("/evasion/ransomware-payment-evasion", "monthly", "0.8", "Ransomware Payment Evasion"), + ("/evasion/virtual-asset-service-provider-evasion", "monthly", "0.8", "Virtual Asset Service Provider Evasion"), + ("/evasion/diplomatic-pouch-courier-evasion", "monthly", "0.8", "Diplomatic Pouch Courier Evasion"), + ("/evasion/shipping-flag-hopping-evasion", "monthly", "0.8", "Shipping Flag Hopping Evasion"), + ("/evasion/digital-currency-stablecoin-evasion", "monthly", "0.8", "Digital Currency Stablecoin Evasion"), + ("/evasion/gift-card-prepaid-card-evasion", "monthly", "0.8", "Gift Card Prepaid Card Evasion"), + ("/evasion/nft-digital-asset-evasion", "monthly", "0.8", "Nft Digital Asset Evasion"), + ("/evasion/decentralized-exchange-evasion", "monthly", "0.8", "Decentralized Exchange Evasion"), + ("/risk-ratings/iran", "monthly", "0.8", "Iran Sanctions Risk Rating"), + ("/risk-ratings/north-korea", "monthly", "0.8", "North Korea Sanctions Risk Rating"), + ("/risk-ratings/syria", "monthly", "0.8", "Syria Sanctions Risk Rating"), + ("/risk-ratings/cuba", "monthly", "0.8", "Cuba Sanctions Risk Rating"), + ("/risk-ratings/russia", "monthly", "0.8", "Russia Sanctions Risk Rating"), + ("/risk-ratings/belarus", "monthly", "0.8", "Belarus Sanctions Risk Rating"), + ("/risk-ratings/venezuela", "monthly", "0.8", "Venezuela Sanctions Risk Rating"), + ("/risk-ratings/myanmar", "monthly", "0.8", "Myanmar Sanctions Risk Rating"), + ("/risk-ratings/china", "monthly", "0.8", "China Sanctions Risk Rating"), + ("/risk-ratings/turkey", "monthly", "0.8", "Turkey Sanctions Risk Rating"), + ("/risk-ratings/uae", "monthly", "0.8", "Uae Sanctions Risk Rating"), + ("/risk-ratings/pakistan", "monthly", "0.8", "Pakistan Sanctions Risk Rating"), + ("/risk-ratings/india", "monthly", "0.8", "India Sanctions Risk Rating"), + ("/risk-ratings/brazil", "monthly", "0.8", "Brazil Sanctions Risk Rating"), + ("/risk-ratings/singapore", "monthly", "0.8", "Singapore Sanctions Risk Rating"), + ("/best/best-ofac-screening-for-fintech", "weekly", "0.9", "Best OFAC Screening For Fintech"), + ("/best/best-sanctions-screening-for-crypto-exchanges", "weekly", "0.9", "Best Sanctions Screening For Crypto Exchanges"), + ("/best/best-sanctions-screening-for-defi-protocols", "weekly", "0.9", "Best Sanctions Screening For Defi Protocols"), + ("/best/best-sanctions-screening-for-marketplaces", "weekly", "0.9", "Best Sanctions Screening For Marketplaces"), + ("/best/best-sanctions-screening-for-psps", "weekly", "0.9", "Best Sanctions Screening For PSPs"), + ("/best/best-ofac-screening-for-ai-agents", "weekly", "0.9", "Best OFAC Screening For AI Agents"), + ("/best/best-sanctions-screening-for-banks", "weekly", "0.9", "Best Sanctions Screening For Banks"), + ("/best/best-sanctions-screening-for-insurance", "weekly", "0.9", "Best Sanctions Screening For Insurance"), + ("/best/best-sanctions-screening-for-ecommerce", "weekly", "0.9", "Best Sanctions Screening For Ecommerce"), + ("/best/best-sanctions-screening-for-startups", "weekly", "0.9", "Best Sanctions Screening For Startups"), ] import datetime today = datetime.date.today().isoformat() diff --git a/best/best-ofac-screening-for-ai-agents/index.html b/best/best-ofac-screening-for-ai-agents/index.html new file mode 100644 index 0000000..e5532ef --- /dev/null +++ b/best/best-ofac-screening-for-ai-agents/index.html @@ -0,0 +1,64 @@ + + +
+ + +AI agents that process payments need sanctions screening built into their payment path. This guide covers the unique compliance requirements for autonomous agent payment systems.
+Traditional sanctions screening is designed for human-initiated transactions with human review of alerts. AI agents operate autonomously, processing payments at machine speed. The compliance gap: who screens the agent's transactions when there is no human in the loop?
+| Requirement | Why | SanctionsAI capability |
|---|---|---|
| API-first integration | Agents call APIs, not use dashboards | REST API with sub-200ms response |
| Real-time screening | Agents process payments at machine speed | Per-transaction API call |
| Wallet screening | Agents use crypto payment paths | OFAC SDN wallet address database |
| Name/entity screening | Agents interact with named counterparties | Name and entity fuzzy matching |
| Autonomous decision-making | Agents must decide block/proceed without human input | Boolean API response (blocked/clean) |
| Audit trail | Every agent decision must be logged | Per-check audit log with timestamp |
The recommended pattern: before executing any payment, the agent calls the sanctions screening API with the counterparty's wallet or name. If the response indicates a match, the agent blocks the payment and logs the event. This creates an autonomous compliance layer.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to Best Of · SanctionsAI
+ \ No newline at end of file diff --git a/best/best-ofac-screening-for-fintech/index.html b/best/best-ofac-screening-for-fintech/index.html new file mode 100644 index 0000000..9bdea66 --- /dev/null +++ b/best/best-ofac-screening-for-fintech/index.html @@ -0,0 +1,62 @@ + + + + + +Fintech companies need sanctions screening that integrates with modern payment infrastructure via API, handles high transaction volumes, and scales without enterprise pricing. This guide compares the top options.
+| Tool | Best for | Pricing model | API-first |
|---|---|---|---|
| SanctionsAI | AI agent payment paths, real-time wallet screening | Per-check, no minimum | Yes |
| Chainalysis KYT | Crypto-native fintechs | Enterprise pricing | Yes |
| SumSub | KYC + sanctions bundle | Per-verification | Yes |
| ComplyAdvantage | Global AML + sanctions | Annual subscription | Yes |
| Elliptic | Crypto compliance | Enterprise pricing | Yes |
| Refinitiv World-Check | Traditional financial institutions | Annual subscription | Yes (but heavier integration) |
Fintech compliance teams should evaluate sanctions screening on: (1) API quality and documentation, (2) real-time screening speed (sub-second for payment flows), (3) list coverage (OFAC SDN, EU, UN, UK HMT), (4) pricing model (per-check vs. subscription), (5) webhook/alert capabilities.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to Best Of · SanctionsAI
+ \ No newline at end of file diff --git a/best/best-sanctions-screening-for-banks/index.html b/best/best-sanctions-screening-for-banks/index.html new file mode 100644 index 0000000..98b3266 --- /dev/null +++ b/best/best-sanctions-screening-for-banks/index.html @@ -0,0 +1,62 @@ + + + + + +Banks face the most comprehensive sanctions screening requirements of any financial institution. This guide covers enterprise screening platforms and compliance requirements specific to banking.
+Banks must screen: (1) all customers at onboarding and periodically, (2) all wire transfers (Fedwire, CHIPS, SWIFT), (3) correspondent banking partners, (4) trade finance transactions, (5) employee and vendor lists. Screening must be real-time for transaction processing and batch for customer list maintenance.
+| Platform | Best for | Strengths | Pricing |
|---|---|---|---|
| Refinitiv World-Check One | Large banks | Most comprehensive list database | $$$$ |
| Dow Jones Risk & Compliance | Global banks | PEP and adverse media coverage | $$$$ |
| Actimize (NICE) | Banks with AML suites | Integrated transaction monitoring | $$$$ |
| SAS Anti-Money Laundering | Large institutions | Full AML platform | $$$$ |
| ComplyAdvantage | Mid-size banks | AI-driven screening | $$$ |
Banks typically use these enterprise platforms for name/entity screening. For crypto wallet screening (increasingly needed as banks explore crypto), SanctionsAI provides specialized wallet-by-wallet screening that complements these platforms.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to Best Of · SanctionsAI
+ \ No newline at end of file diff --git a/best/best-sanctions-screening-for-crypto-exchanges/index.html b/best/best-sanctions-screening-for-crypto-exchanges/index.html new file mode 100644 index 0000000..5e17f04 --- /dev/null +++ b/best/best-sanctions-screening-for-crypto-exchanges/index.html @@ -0,0 +1,61 @@ + + + + + +Crypto exchanges (VASPs) face the strictest sanctions screening requirements because crypto is the primary medium for sanctions evasion. This guide compares the tools designed for crypto-native compliance.
+| Tool | Crypto coverage | Best for | Pricing |
|---|---|---|---|
| Chainalysis KYT | BTC, ETH, USDT, 100+ chains | Enterprise exchanges | $$$ |
| Elliptic | BTC, ETH, major stablecoins | Enterprise exchanges | $$$ |
| TRM Labs | Multi-chain, DeFi | Enterprise exchanges | $$$ |
| SanctionsAI | OFAC SDN wallets, multi-chain | Agent payment paths, startups | $ |
| SumSub | KYC + wallet screening | Mid-tier exchanges | $$ |
Crypto exchanges must screen: (1) customer wallet addresses against OFAC designated crypto addresses, (2) transaction counterparty addresses in real-time, (3) deposit/withdrawal history for mixer interaction, (4) wallet risk scoring (proximity to known illicit addresses).
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to Best Of · SanctionsAI
+ \ No newline at end of file diff --git a/best/best-sanctions-screening-for-defi-protocols/index.html b/best/best-sanctions-screening-for-defi-protocols/index.html new file mode 100644 index 0000000..60d5714 --- /dev/null +++ b/best/best-sanctions-screening-for-defi-protocols/index.html @@ -0,0 +1,60 @@ + + + + + +DeFi protocols face a unique compliance paradox: smart contracts are permissionless and cannot enforce KYC, but front-ends and governance DAOs have legal obligations. This guide covers the available approaches.
+| Approach | How it works | Pros | Cons |
|---|---|---|---|
| Front-end wallet screening | Block designated wallets at the UI level | Simple, immediate | Trivially bypassed (direct contract interaction) |
| Oracle-based blocking | Smart contract reads sanctions oracle before execution | Enforced at protocol level | Gas cost; centralization risk in oracle |
| Geofencing | Block users from sanctioned jurisdictions via IP | Reduces exposure | VPN bypass; over-blocking |
| Post-hoc monitoring | Monitor for designated address interaction, report | Preserves composability | Does not prevent violation |
OFAC has not published DeFi-specific regulations but its sanctions apply to all US persons. The Tornado Cash designation (2022) demonstrated that OFAC considers smart contract interaction sanctions-relevant. The Fifth Circuit's 2024 ruling created uncertainty, but compliance teams should assume DeFi interaction with designated addresses carries risk.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to Best Of · SanctionsAI
+ \ No newline at end of file diff --git a/best/best-sanctions-screening-for-ecommerce/index.html b/best/best-sanctions-screening-for-ecommerce/index.html new file mode 100644 index 0000000..a38a4ba --- /dev/null +++ b/best/best-sanctions-screening-for-ecommerce/index.html @@ -0,0 +1,61 @@ + + + + + +E-commerce platforms must screen customers, block shipments to sanctioned jurisdictions, and ensure payment routing does not violate OFAC. This guide covers e-commerce-specific compliance requirements.
+| Risk area | Description | Screening approach |
|---|---|---|
| Customer screening | Customer or shipping address in sanctioned jurisdiction | Geographic screening at checkout |
| SDN-listed customers | Customer name matches OFAC SDN list | Name screening at account creation |
| Payment screening | Payment from sanctioned bank or crypto wallet | Bank BIN screening, wallet address screening |
| Drop-shipping risk | Supplier or fulfillment partner in sanctioned jurisdiction | Supplier screening at onboarding |
| Export controlled items | Items subject to EAR or ITAR shipped to embargoed destination | Product classification + destination screening |
The minimum compliance control for e-commerce is geographic blocking: prevent orders from shipping to comprehensively sanctioned jurisdictions (Iran, North Korea, Syria, Cuba, Crimea/DNR/LNR). This should be enforced at checkout via shipping address validation.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to Best Of · SanctionsAI
+ \ No newline at end of file diff --git a/best/best-sanctions-screening-for-insurance/index.html b/best/best-sanctions-screening-for-insurance/index.html new file mode 100644 index 0000000..44fd524 --- /dev/null +++ b/best/best-sanctions-screening-for-insurance/index.html @@ -0,0 +1,59 @@ + + + + + +Insurance companies must screen policyholders, beneficiaries, and claimants against OFAC sanctions lists. This guide covers insurance-specific screening requirements.
+OFAC regulations apply to insurance companies in three areas: (1) policy issuance, (2) premium collection, (3) claims payment. A policy issued to a designated person, a premium accepted from a sanctioned entity, or a claim paid to a beneficiary in a sanctioned jurisdiction all constitute violations.
+| Screening point | What to screen | Frequency |
|---|---|---|
| Policy issuance | Policyholder name, beneficiary names | At application |
| Premium collection | Payment source, payer name | Per payment |
| Claims payment | Claimant name, payee name, payment destination | Per claim |
| Periodic rescreening | All active policyholders | Daily/weekly batch |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to Best Of · SanctionsAI
+ \ No newline at end of file diff --git a/best/best-sanctions-screening-for-marketplaces/index.html b/best/best-sanctions-screening-for-marketplaces/index.html new file mode 100644 index 0000000..d87d608 --- /dev/null +++ b/best/best-sanctions-screening-for-marketplaces/index.html @@ -0,0 +1,61 @@ + + + + + +Online marketplaces face sanctions risk from both sides: sellers operating from sanctioned jurisdictions and buyers routing payments through sanctioned entities. This guide covers marketplace-specific compliance approaches.
+| Risk vector | Description | Mitigation |
|---|---|---|
| Seller from sanctioned jurisdiction | Seller located in or operating from Iran, North Korea, Syria, Cuba, Crimea | Geographic screening at registration |
| Seller is SDN-listed | Individual or entity on OFAC SDN list | Name screening at onboarding |
| Buyer payment from sanctioned wallet | Crypto payment from OFAC-designated wallet address | Wallet screening for crypto payments |
| Shipping to sanctioned jurisdiction | Physical goods shipped to comprehensively sanctioned countries | Address screening at checkout |
| Payment to sanctioned bank | Seller payout routed through designated financial institution | Bank screening at payout configuration |
Marketplaces need both name screening (for sellers) and wallet screening (for crypto payments). SanctionsAI covers both with a single API. For KYC-bundled solutions, SumSub and ComplyAdvantage offer marketplace-specific packages.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to Best Of · SanctionsAI
+ \ No newline at end of file diff --git a/best/best-sanctions-screening-for-psps/index.html b/best/best-sanctions-screening-for-psps/index.html new file mode 100644 index 0000000..e224fda --- /dev/null +++ b/best/best-sanctions-screening-for-psps/index.html @@ -0,0 +1,59 @@ + + + + + +Payment service providers (PSPs) sit at the intersection of buyer and seller, making sanctions screening critical. This guide covers the screening requirements specific to PSPs.
+PSPs must screen: (1) merchant names at onboarding, (2) individual transactions in real-time, (3) beneficiary names for outbound payments, (4) correspondent banking partners. The velocity of transactions requires sub-second screening.
+| Screening type | When | Latency requirement | Tool recommendation |
|---|---|---|---|
| Merchant onboarding | At signup | Seconds (not blocking) | Batch screening, ComplyAdvantage or Refinitiv |
| Real-time transaction screening | Per transaction | Sub-second | SanctionsAI API or SumSub |
| Beneficiary screening | Per outbound payment | Sub-second | SanctionsAI API |
| Crypto wallet screening | Per crypto transaction | Sub-second | SanctionsAI wallet API |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to Best Of · SanctionsAI
+ \ No newline at end of file diff --git a/best/best-sanctions-screening-for-startups/index.html b/best/best-sanctions-screening-for-startups/index.html new file mode 100644 index 0000000..5e7279b --- /dev/null +++ b/best/best-sanctions-screening-for-startups/index.html @@ -0,0 +1,61 @@ + + + + + +Startups need sanctions screening that is affordable, easy to integrate, and has no minimum volume requirements. This guide covers the best options for early-stage companies.
+| Tool | Pricing model | Minimum | Integration | Best for |
|---|---|---|---|---|
| SanctionsAI | Per-check ($0.001-$0.10) | None | REST API, 5 minutes | Startups with any payment flow |
| SumSub | Per-verification ($1-$5) | Low | API + SDK | KYC + sanctions bundle |
| ComplyAdvantage | Annual ($10K+) | $$ | API | Funded startups |
| Refinitiv World-Check | Annual ($25K+) | $$$ | Enterprise integration | Not suitable for pre-Series A |
| Free OFAC list download | Free | None | Manual scripting | Prototypes only |
The OFAC SDN list is freely downloadable. Startups sometimes build their own screening using this data. This approach has critical problems: (1) no fuzzy matching (typos and aliases are missed), (2) no crypto address coverage, (3) no update guarantee, (4) no audit trail, (5) no compliance documentation for regulators or enterprise customers.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to Best Of · SanctionsAI
+ \ No newline at end of file diff --git a/evasion/cross-chain-bridge-evasion/index.html b/evasion/cross-chain-bridge-evasion/index.html new file mode 100644 index 0000000..fce713e --- /dev/null +++ b/evasion/cross-chain-bridge-evasion/index.html @@ -0,0 +1,60 @@ + + + + + +Cross-chain bridges let users move assets between blockchains, breaking the on-chain trail that sanctions screening tools follow. OFAC designated the Tornado Cash bridge in 2022, proving bridges are sanctions-relevant infrastructure.
+TL;DR: Cross-chain bridges create a fundamental screening gap: a wallet flagged on Ethereum can move USDC to Solana via a bridge, appearing as a clean address on the destination chain. Compliance teams must screen both the source address and the bridge recipient.
+A sanctioned entity deposits funds into a bridge contract on Chain A. The bridge locks or burns those tokens and mints equivalent tokens on Chain B. The recipient on Chain B has no direct link to the sanctioned address on Chain A. Standard wallet screening on Chain B alone returns clean.
+The Lazarus Group (North Korea, designated under OFAC's DPRK program) has systematically used cross-chain bridges to launder stolen crypto. OFAC designated Tornado Cash in August 2022 specifically because it was used to process over $455 million in illicit proceeds including funds for the DPRK.
+| Method | What it catches | Limitation |
|---|---|---|
| Source-address screening | Flagged deposits on Chain A | Requires real-time monitoring |
| Bridge contract monitoring | Direct interaction with designated bridge contracts | New bridges appear constantly |
| Destination clustering | Funds arriving on Chain B from flagged Chain A deposits | Timing window is fuzzy |
| Graph analysis | Multi-hop paths through bridges | Computationally expensive |
AI agents processing payments across multiple chains must screen at both source and destination. The recommended control: screen every bridge interaction as a two-leg transaction.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to evasion · SanctionsAI
+ \ No newline at end of file diff --git a/evasion/crypto-mixer-evasion/index.html b/evasion/crypto-mixer-evasion/index.html new file mode 100644 index 0000000..f4ce18a --- /dev/null +++ b/evasion/crypto-mixer-evasion/index.html @@ -0,0 +1,58 @@ + + + + + +Cryptocurrency mixers (tumblers) pool funds from multiple users, mix them, and redistribute them, breaking the deterministic link between input and output addresses. OFAC designated Blender.io (2022) and Tornado Cash (2022), making mixer interaction a direct sanctions violation.
+TL;DR: Mixers are the primary tool for obscuring crypto provenance. OFAC has designated two major mixers as SDN entities, meaning any US person who transacts with them commits a sanctions violation. Compliance teams must screen for mixer interaction in wallet transaction history.
+| Mixer | Designation date | Program | Reason |
|---|---|---|---|
| Blender.io | May 6, 2022 | DPRK | Used by Lazarus Group to launder $20.5M from Axie Infinity hack |
| Tornado Cash | August 8, 2022 | DPRK | Processed $455M+ in illicit proceeds for Lazarus Group |
A mixer accepts deposits from many users into a smart contract. After a delay, users withdraw to new addresses. Because the output addresses are new and the pool obscures which deposit maps to which withdrawal, blockchain analytics cannot deterministically link input to output (for non-custodial mixers like Tornado Cash).
+Without mixer-aware screening, a wallet that received funds from Tornado Cash appears clean. With mixer screening, the wallet is flagged as having interacted with a designated entity.
+Any AI agent accepting crypto payments must screen the transaction history of incoming wallets for interaction with designated mixer contracts. This is not optional: OFAC considers transacting with a designated mixer a violation regardless of whether you knew the mixer was involved.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to evasion · SanctionsAI
+ \ No newline at end of file diff --git a/evasion/decentralized-exchange-evasion/index.html b/evasion/decentralized-exchange-evasion/index.html new file mode 100644 index 0000000..e33c51c --- /dev/null +++ b/evasion/decentralized-exchange-evasion/index.html @@ -0,0 +1,60 @@ + + + + + +Decentralized exchanges (DEXes) allow permissionless crypto trading without KYC. Sanctioned entities use DEXes to swap, trade, and exit positions without interacting with regulated VASPs.
+TL;DR: DEXes (Uniswap, Curve, 1inch) do not require KYC and cannot enforce sanctions screening because they are smart contracts, not entities. OFAC designated the Tornado Cash smart contract in 2022, raising the question of whether DEX smart contracts can be sanctioned. DeFi protocols face increasing compliance pressure.
+Centralized exchanges (CEXes) are regulated VASPs that implement KYC and sanctions screening. DEXes are smart contracts that execute trades automatically. They cannot verify user identity or screen wallets because they have no operator. This creates a fundamental compliance gap.
+OFAC designated Tornado Cash smart contract addresses in 2022, making it a violation for US persons to interact with them. This precedent suggests OFAC may designate DEX smart contracts that are used by sanctioned entities. The Fifth Circuit's 2024 ruling on Tornado Cash created uncertainty about this approach for immutable contracts.
+| DeFi risk vector | How sanctioned entities exploit it | Compliance response |
|---|---|---|
| Permissionless swaps | Trade crypto without KYC via DEX smart contracts | Screen incoming wallets before accepting payments |
| Liquidity pools | Provide liquidity to earn yield on illicit funds | Not currently detectable at the protocol level |
| Flash loans | Borrow and repay in a single transaction for complex evasion | Requires advanced on-chain forensics |
| Governance tokens | Hold governance tokens to influence protocol parameters | Screen governance participants |
AI agents accepting payments should assume that incoming funds may have passed through DEXes. Wallet screening must look at the wallet's direct counterparty, but also flag known DEX-exit patterns (fresh wallets with no history receiving large deposits from DEX router contracts).
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to evasion · SanctionsAI
+ \ No newline at end of file diff --git a/evasion/digital-currency-stablecoin-evasion/index.html b/evasion/digital-currency-stablecoin-evasion/index.html new file mode 100644 index 0000000..178e48f --- /dev/null +++ b/evasion/digital-currency-stablecoin-evasion/index.html @@ -0,0 +1,60 @@ + + + + + +Stablecoins (USDT, USDC, DAI) have become the preferred medium for sanctions evasion because they offer the stability of fiat with the permissionless transfer of crypto. OFAC designations increasingly include stablecoin addresses.
+TL;DR: Stablecoins are the most-used crypto asset for sanctions evasion because they hold value stably and transfer instantly without banking intermediaries. Compliance teams must screen stablecoin transfers the same as any other crypto asset.
+Bitcoin and Ethereum prices are volatile, making them poor stores of value for sanctioned entities who need stability. USDT (Tether) and USDC (Circle) hold their value at $1, making them the practical choice for storing and moving illicit proceeds.
+| Stablecoin | Issuer | Freeze capability | OFAC compliance |
|---|---|---|---|
| USDC | Circle | Yes, issuer can freeze addresses | Freezes OFAC-designated addresses |
| USDT | Tether | Yes, issuer can freeze addresses | Freezes OFAC-designated addresses |
| DAI | MakerDAO | Not centralized (until Endgame) | Cannot freeze (decentralized) |
| BUSD | Paxos | Yes | Freezes OFAC-designated addresses (discontinued minting) |
Centralized stablecoin issuers can freeze addresses, effectively blocking sanctioned entities. Circle has frozen addresses associated with OFAC-designated Tornado Cash. However, freezing only works for centralized stablecoins. Decentralized stablecoins (DAI, LUSD) cannot be frozen by design.
+AI agents accepting stablecoin payments must screen the sending wallet against OFAC addresses, regardless of stablecoin type. Even if USDC has frozen a designated address, the designated entity may use other stablecoins or wrapped tokens.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to evasion · SanctionsAI
+ \ No newline at end of file diff --git a/evasion/diplomatic-pouch-courier-evasion/index.html b/evasion/diplomatic-pouch-courier-evasion/index.html new file mode 100644 index 0000000..b63ec58 --- /dev/null +++ b/evasion/diplomatic-pouch-courier-evasion/index.html @@ -0,0 +1,55 @@ + + + + + +Diplomatic immunity and pouch protections create a legal channel that sanctioned entities can exploit to move cash, precious metals, and documents outside the financial system.
+TL;DR: Sanctioned states and their allies use diplomatic pouches (which cannot be inspected under the Vienna Convention) and diplomatic couriers to move physical value (cash, gold, diamonds) outside the financial system. This is primarily a state-level evasion method, not a corporate compliance concern, but it demonstrates how sanctions evasion extends beyond financial channels.
+The Vienna Convention on Diplomatic Relations (1961) protects diplomatic pouches from inspection. While intended for official communications, sanctioned states can use diplomatic channels to transport: physical cash in multiple currencies, precious metals and stones, bearer instruments, and trade documents for TBML schemes.
+Iran has been documented using diplomatic channels to move cash to evade sanctions. North Korea's diplomatic missions have been used for sanctions evasion including cash couriers. These cases are typically addressed through diplomatic expulsions and secondary sanctions on individuals, not through corporate compliance.
+This evasion method is largely irrelevant to AI agent payments (which are digital). However, compliance teams should be aware that physical value transfer exists as a sanctions evasion vector, particularly when assessing counterparties in comprehensively sanctioned jurisdictions who may have diplomatic connections.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to evasion · SanctionsAI
+ \ No newline at end of file diff --git a/evasion/gift-card-prepaid-card-evasion/index.html b/evasion/gift-card-prepaid-card-evasion/index.html new file mode 100644 index 0000000..dfa0f91 --- /dev/null +++ b/evasion/gift-card-prepaid-card-evasion/index.html @@ -0,0 +1,59 @@ + + + + + +Gift cards and prepaid cards are an underappreciated sanctions evasion channel. They move value outside the banking system, are difficult to trace, and can be purchased with cash or crypto.
+TL;DR: Stored value instruments (gift cards, prepaid cards) let sanctioned entities move small-to-medium value across borders without triggering financial monitoring. While lower-volume than crypto or TBML, gift cards are harder to detect because they operate through retail, not financial channels.
+Sanctioned entities or their proxies purchase gift cards (Amazon, Apple, Google Play, Visa/Mastercard prepaid) with crypto or cash in one jurisdiction, then sell or use them in another. The value moves through retail systems that are not subject to OFAC screening or SAR reporting in the same way as financial transfers.
+Open-loop prepaid cards (Visa/Mastercard branded) are higher risk than closed-loop (store-specific) because they can be used anywhere. FinCEN regulates prepaid access under 31 CFR 1010.100, with KYC requirements for certain thresholds, but compliance varies by issuer.
+| Instrument | Typical value | Detection difficulty | OFAC screening |
|---|---|---|---|
| Retail gift cards | $100-$500 | High (retail, not financial) | Not screened at point of sale |
| Open-loop prepaid cards | $500-$5,000 | Medium (regulated by FinCEN) | Issuer-dependent KYC |
| Crypto-purchased gift cards | $50-$2,000 | Very high (bridge between crypto and retail) | Platform-dependent |
AI agents processing payments are unlikely to handle gift card transactions directly. However, agents serving e-commerce platforms should be aware that bulk gift card purchases with crypto are a sanctions evasion red flag, particularly when shipped to high-risk jurisdictions.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to evasion · SanctionsAI
+ \ No newline at end of file diff --git a/evasion/nft-digital-asset-evasion/index.html b/evasion/nft-digital-asset-evasion/index.html new file mode 100644 index 0000000..9a349be --- /dev/null +++ b/evasion/nft-digital-asset-evasion/index.html @@ -0,0 +1,60 @@ + + + + + +NFTs and tokenized digital assets can be used to move value by assigning arbitrary prices to unique tokens, creating a channel that evades traditional sanctions screening focused on fungible tokens.
+TL;DR: NFTs (non-fungible tokens) create a sanctions evasion risk because their value is subjective. A sanctioned entity can mint an NFT, have an associate buy it for a high price, and move value without triggering wallet screening (which typically focuses on fungible token transfers).
+A designated entity mints an NFT (art, collectible, or arbitrary digital asset). An associate purchases the NFT for a high price. The payment appears as a legitimate marketplace transaction. Because NFT prices are subjective, there is no objective market rate to flag as anomalous, unlike TBML for physical goods.
+OFAC has not specifically designated NFT marketplaces, but its sanctions apply to all transactions by US persons. An NFT sale to a designated entity is a sanctions violation. NFT marketplaces (OpenSea, Blur, Magic Eden) implement wallet screening to block designated addresses.
+| Risk vector | How it works | Detection |
|---|---|---|
| Wash trading | Sell NFT to self via different wallets to create apparent market value | On-chain clustering analysis |
| Value transfer via NFT | Designated entity mints, associate buys at inflated price | Screen buyer wallets for OFAC exposure |
| NFT as collateral | Use NFT as collateral for a loan in DeFi, withdraw funds | Screen borrower wallets |
| Fractionalized NFTs | Split high-value NFT into fungible tokens that trade on DEXes | Treat as fungible token; screen addresses |
NFT marketplaces should screen both buyer and seller wallets against OFAC SDN addresses. For AI agents involved in NFT transactions (rare but possible), the same wallet screening applies.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to evasion · SanctionsAI
+ \ No newline at end of file diff --git a/evasion/ransomware-payment-evasion/index.html b/evasion/ransomware-payment-evasion/index.html new file mode 100644 index 0000000..1347dd0 --- /dev/null +++ b/evasion/ransomware-payment-evasion/index.html @@ -0,0 +1,60 @@ + + + + + +Paying ransomware to sanctioned entities or jurisdictions is an OFAC violation. OFAC issued an Updated Advisory on Ransomware Regarding the Use of the Financial System for Facilitating Ransomware Payments in 2021.
+TL;DR: Companies paying ransomware demands can face OFAC penalties if the recipient is a designated entity or located in a comprehensively sanctioned jurisdiction. OFAC's 2021 advisory warns that ransomware payments to sanctioned actors constitute sanctions violations regardless of intent.
+In September 2021, OFAC published an updated advisory making clear that paying ransomware to sanctioned entities, including those in comprehensively embargoed jurisdictions (Cuba, Iran, North Korea, Syria, Crimea/DNR/LNR), violates sanctions. The advisory offers a safe harbor for voluntary self-disclosure.
+OFAC has designated multiple ransomware operators and associated crypto exchange services under various programs. Notable examples include actors linked to Evil Corp, the Lazarus Group, and darknet markets like Hydra. Each designation means US persons cannot pay them, even under ransomware extortion.
+| Risk factor | OFAC implication |
|---|---|
| Ransomware actor is SDN-listed | Payment is a direct sanctions violation |
| Payment routed through comprehensively sanctioned jurisdiction | Violation regardless of recipient identity |
| Payment to known ransomware affiliate in non-sanctioned jurisdiction | Legal but high-risk; may facilitate future sanctions evasion |
| Voluntary self-disclosure of accidental payment to SDN | May qualify for mitigation under OFAC enforcement guidelines |
OFAC's enforcement guidelines provide significantly reduced penalties for entities that voluntarily self-disclose apparent violations. The 2021 ransomware advisory explicitly encourages self-disclosure of payments to designated entities, with a presumption of mitigation for voluntary reporting.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to evasion · SanctionsAI
+ \ No newline at end of file diff --git a/evasion/shell-company-front-companies/index.html b/evasion/shell-company-front-companies/index.html new file mode 100644 index 0000000..a91a637 --- /dev/null +++ b/evasion/shell-company-front-companies/index.html @@ -0,0 +1,59 @@ + + + + + +Shell companies and front companies are the oldest sanctions evasion tool. OFAC's 50 Percent Rule makes any entity owned 50% or more by a designated person itself designated, but proving ownership through layers of shell companies is the enforcement challenge.
+TL;DR: Sanctioned individuals create layered corporate structures across multiple jurisdictions to obscure beneficial ownership. OFAC's 50 Percent Rule means any entity majority-owned by a designated person is also blocked, even if not separately listed. The challenge is identifying the ownership chain.
+Under OFAC regulations, any entity that is 50% or more owned, directly or indirectly, by a designated person is itself considered designated, even if not separately listed on the SDN list. This means a shell company 51% owned by an SDN is blocked property, even if its name does not appear on any sanctions list.
+| Structure | How it works | Jurisdictions commonly used |
|---|---|---|
| Nominee director | Designated person controls through a strawman director | BVI, Seychelles, Panama |
| Trust and corporate service provider | Professional intermediary holds shares on behalf of designated person | Cyprus, UAE, Cayman Islands |
| Layered holding companies | Multiple holding entities across jurisdictions to break ownership chain | Delaware, Luxembourg, Singapore |
| Joint venture dilution | Designated person holds exactly 49% to fall below threshold | Various |
OFAC designated Oleg Deripaska in 2018 under the Russia sanctions program. Subsequent designations of his companies (EN+ Group, Rusal, ESE) demonstrated how OFAC extends the SDN list through the 50 Percent Rule. EN+ Group restructured its ownership to reduce Deripaska's stake below 50% to achieve delisting, showing the Rule works both ways.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to evasion · SanctionsAI
+ \ No newline at end of file diff --git a/evasion/shipping-flag-hopping-evasion/index.html b/evasion/shipping-flag-hopping-evasion/index.html new file mode 100644 index 0000000..659e867 --- /dev/null +++ b/evasion/shipping-flag-hopping-evasion/index.html @@ -0,0 +1,58 @@ + + + + + +Maritime sanctions evasion involves ship-to-ship (STS) transfers at sea, AIS signal manipulation, and flag hopping to disguise the origin of sanctioned commodities like Iranian and North Korean oil.
+TL;DR: OFAC has issued multiple advisories on maritime sanctions evasion. Sanctioned entities use STS transfers to blend sanctioned oil with legitimate cargo, disable AIS (Automatic Identification System) to hide ship locations, and repeatedly change vessel flags to evade tracking.
+OFAC, in coordination with the State Department and Coast Guard, has published detailed advisories on illicit maritime activity including: the Iran shipping advisory (2020), the North Korea shipping advisory (2018, updated), and the Global Maritime Sanctions Advisory (2021). These advise the shipping, insurance, and financial sectors on detecting sanctions evasion.
+| Method | How it works | OFAC advisory response |
|---|---|---|
| STS transfers at sea | Sanctioned cargo transferred between ships in international waters to disguise origin | Screen STS locations and dates; flag transfers in high-risk areas |
| AIS disabling | Ships turn off tracking before entering sanctioned ports or conducting illicit transfers | Treat AIS gaps as red flags; require continuous tracking |
| Flag hopping | Vessels repeatedly change flag state to evade tracking or sanctions enforcement | Screen vessel IMO numbers, not just flag state |
Maritime sanctions evasion is relevant to compliance teams in shipping, trade finance, and insurance. For AI agents handling digital payments, this is a lower-priority vector, but agents processing trade finance documentation or shipping payments should be aware of STS transfer red flags.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to evasion · SanctionsAI
+ \ No newline at end of file diff --git a/evasion/trade-based-money-laundering/index.html b/evasion/trade-based-money-laundering/index.html new file mode 100644 index 0000000..217d2db --- /dev/null +++ b/evasion/trade-based-money-laundering/index.html @@ -0,0 +1,59 @@ + + + + + +Trade-based money laundering (TBML) is the most common method sanctioned entities use to move value across borders without triggering financial controls. FATF identifies it as one of the three main money laundering methods.
+TL;DR: TBML moves value through international trade transactions by manipulating invoice prices, shipping phantom goods, or using front importers. Sanctioned entities use TBML to access the financial system indirectly, because trade finance is less scrutinized than direct wire transfers.
+| Method | How it works | Red flag |
|---|---|---|
| Over-invoicing | Importer overpays exporter; difference = value transfer | Price far above market rate for the commodity |
| Under-invoicing | Exporter undercharges importer; difference = value transfer on import side | Price far below market rate |
| Phantom shipments | Invoice for goods that never ship; pure paper transaction | No shipping documents, no customs records |
| Multiple invoicing | Same shipment invoiced multiple times to justify multiple payments | Duplicate invoices for one bill of lading |
OFAC's sanctions on Iran, North Korea, and Russia have repeatedly targeted TBML networks. The 2020 designation of a network of front companies based in the UAE, Hong Kong, and Singapore that facilitated Iranian TBML showed how these networks operate across multiple jurisdictions.
+TBML detection requires comparing transaction prices against market benchmarks. For AI agent payments, the risk is lower (agents typically do not process trade invoices), but any agent handling B2B payments should validate that payment amounts correspond to verifiable goods or services.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to evasion · SanctionsAI
+ \ No newline at end of file diff --git a/evasion/virtual-asset-service-provider-evasion/index.html b/evasion/virtual-asset-service-provider-evasion/index.html new file mode 100644 index 0000000..263687b --- /dev/null +++ b/evasion/virtual-asset-service-provider-evasion/index.html @@ -0,0 +1,60 @@ + + + + + +Virtual Asset Service Providers (VASPs) are crypto exchanges, custodial wallets, and payment processors. Unlicensed or poorly regulated VASPs in high-risk jurisdictions are a primary channel for sanctioned entities to convert crypto to fiat.
+TL;DR: Sanctioned entities use under-regulated VASPs to cash out crypto into fiat currency, bypassing the compliance controls of regulated exchanges. The FATF Travel Rule is designed to close this gap but adoption is incomplete.
+A designated entity cannot use regulated exchanges like Coinbase or Binance (they screen against OFAC SDN). Instead, they use: (1) unlicensed P2P exchanges in high-risk jurisdictions, (2) nested exchanges operating under another VASP's license, (3) exchanges in jurisdictions with weak sanctions enforcement.
+The FATF Travel Rule (Recommendation 16) requires VASPs to share sender and recipient information for transactions above USD/EUR 1,000. This creates an audit trail that sanctions screening can use. However, implementation is incomplete: many jurisdictions have not enacted Travel Rule legislation, creating gaps.
+| VASP risk tier | Characteristics | Sanctions risk |
|---|---|---|
| Low | Licensed in FATF-compliant jurisdiction, screens against SDN | Minimal |
| Medium | Licensed but in weak-enforcement jurisdiction, limited screening | Moderate |
| High | Unlicensed or nested under another VASP's license | Significant |
| Critical | Located in or serving comprehensively sanctioned jurisdiction | Severe, do not transact |
OFAC has designated multiple VASPs for facilitating sanctions evasion, including Suex (2021), Chatex (2021), and Garantex (2022). These designations make it a sanctions violation for any US person to transact with these exchanges, including sending or receiving crypto to/from their addresses.
+Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to evasion · SanctionsAI
+ \ No newline at end of file diff --git a/risk-ratings/belarus/index.html b/risk-ratings/belarus/index.html new file mode 100644 index 0000000..64bfb57 --- /dev/null +++ b/risk-ratings/belarus/index.html @@ -0,0 +1,66 @@ + + + + + +Belarus is subject to extensive targeted sanctions aligned with Russia sanctions, plus Belarus-specific human rights and election fraud sanctions.
+Belarus faces extensive sanctions under EO 14038 (Belarus) in addition to Russia-aligned measures. Key sectors affected include potash, timber, steel, and tobacco. The Belarusian government, military, and state-owned enterprises are designated following the 2020 election fraud and 2022 support for Russia's invasion of Ukraine.
+| Screening action | Priority |
|---|---|
| Screen all counterparties against OFAC SDN list | Critical |
| Enhanced due diligence on beneficial ownership | Recommended |
| Screen transaction routes for sanctioned jurisdictions | Recommended |
| Monitor for evasion patterns (shell companies, TBML) | Critical |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to risk-ratings · SanctionsAI
+ \ No newline at end of file diff --git a/risk-ratings/brazil/index.html b/risk-ratings/brazil/index.html new file mode 100644 index 0000000..e8d7384 --- /dev/null +++ b/risk-ratings/brazil/index.html @@ -0,0 +1,66 @@ + + + + + +Brazil is not subject to OFAC sanctions. Minimal sanctions risk. General commercial transactions are permitted.
+Brazil is not subject to any OFAC sanctions programs. There are minimal individual designations related to corruption (under Global Magnitsky). Commercial transactions with Brazilian counterparties carry minimal sanctions risk. Standard due diligence applies.
+| Screening action | Priority |
|---|---|
| Screen all counterparties against OFAC SDN list | Standard |
| Enhanced due diligence on beneficial ownership | Standard |
| Screen transaction routes for sanctioned jurisdictions | Recommended |
| Monitor for evasion patterns (shell companies, TBML) | Recommended |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to risk-ratings · SanctionsAI
+ \ No newline at end of file diff --git a/risk-ratings/china/index.html b/risk-ratings/china/index.html new file mode 100644 index 0000000..ec773ca --- /dev/null +++ b/risk-ratings/china/index.html @@ -0,0 +1,66 @@ + + + + + +China is subject to targeted sanctions on specific entities and individuals related to human rights abuses, military-civil fusion, and fentanyl. Not comprehensively sanctioned.
+China is NOT comprehensively sanctioned. Targeted sanctions address specific concerns: human rights abuses in Xinjiang (UFLPA, EO 13959), military-civil fusion (NS-CMIC list), fentanyl trafficking, and Hong Kong autonomy erosion. Most trade with China is permitted. Compliance teams should screen counterparties against the SDN list and NS-CMIC list.
+| Screening action | Priority |
|---|---|
| Screen all counterparties against OFAC SDN list | Standard |
| Enhanced due diligence on beneficial ownership | Recommended |
| Screen transaction routes for sanctioned jurisdictions | Recommended |
| Monitor for evasion patterns (shell companies, TBML) | Recommended |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to risk-ratings · SanctionsAI
+ \ No newline at end of file diff --git a/risk-ratings/cuba/index.html b/risk-ratings/cuba/index.html new file mode 100644 index 0000000..f9eb8ce --- /dev/null +++ b/risk-ratings/cuba/index.html @@ -0,0 +1,66 @@ + + + + + +Cuba is subject to comprehensive US sanctions under the Cuban Assets Control Regulations (CACR). While some restrictions have been eased over the years, the core embargo remains in effect.
+The CACR (31 CFR Part 515) implements the US embargo on Cuba. While the Obama administration eased certain restrictions and the Biden administration has made further modifications, the core embargo remains. Most transactions between US persons and Cuba are prohibited, with limited exceptions.
+| Screening action | Priority |
|---|---|
| Screen all counterparties against OFAC SDN list | Critical |
| Enhanced due diligence on beneficial ownership | Critical |
| Screen transaction routes for sanctioned jurisdictions | Critical |
| Monitor for evasion patterns (shell companies, TBML) | Critical |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to risk-ratings · SanctionsAI
+ \ No newline at end of file diff --git a/risk-ratings/india/index.html b/risk-ratings/india/index.html new file mode 100644 index 0000000..1188662 --- /dev/null +++ b/risk-ratings/india/index.html @@ -0,0 +1,66 @@ + + + + + +India is not comprehensively sanctioned but faces limited designations related to defense trade with Russia and specific entities.
+India is not sanctioned by OFAC. The main sanctions-adjacent risk is CAATSA exposure for India's purchase of Russian defense systems (S-400), though a waiver has been applied. Most commercial transactions with India are permitted without sanctions risk.
+| Screening action | Priority |
|---|---|
| Screen all counterparties against OFAC SDN list | Standard |
| Enhanced due diligence on beneficial ownership | Standard |
| Screen transaction routes for sanctioned jurisdictions | Recommended |
| Monitor for evasion patterns (shell companies, TBML) | Recommended |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to risk-ratings · SanctionsAI
+ \ No newline at end of file diff --git a/risk-ratings/iran/index.html b/risk-ratings/iran/index.html new file mode 100644 index 0000000..0708c86 --- /dev/null +++ b/risk-ratings/iran/index.html @@ -0,0 +1,66 @@ + + + + + +Iran is subject to comprehensive US sanctions under the Iranian Transactions and Sanctions Regulations (ITSR). All transactions by US persons with Iran are prohibited.
+The ITSR (31 CFR Part 560) prohibits virtually all transactions between US persons and Iran. This includes imports, exports, investments, and financial transactions. OFAC administers additional Iran-specific programs including Iran Human Rights and Iran Weapons of Mass Destruction sanctions. Secondary sanctions apply to non-US foreign persons who conduct significant transactions with Iran's energy, shipping, shipbuilding, or financial sectors.
+| Screening action | Priority |
|---|---|
| Screen all counterparties against OFAC SDN list | Critical |
| Enhanced due diligence on beneficial ownership | Critical |
| Screen transaction routes for sanctioned jurisdictions | Critical |
| Monitor for evasion patterns (shell companies, TBML) | Critical |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to risk-ratings · SanctionsAI
+ \ No newline at end of file diff --git a/risk-ratings/myanmar/index.html b/risk-ratings/myanmar/index.html new file mode 100644 index 0000000..6ff14c5 --- /dev/null +++ b/risk-ratings/myanmar/index.html @@ -0,0 +1,66 @@ + + + + + +Myanmar is subject to targeted sanctions following the 2021 military coup. Military junta leaders, defense ministry, and state-owned enterprises are designated.
+Following the February 2021 military coup, the US imposed targeted sanctions on Myanmar's military leadership and associated entities under EO 14014. Designations include the State Administration Council, military officials, and state-owned enterprises. The sanctions focus on the military regime rather than comprehensive trade restrictions.
+| Screening action | Priority |
|---|---|
| Screen all counterparties against OFAC SDN list | Critical |
| Enhanced due diligence on beneficial ownership | Recommended |
| Screen transaction routes for sanctioned jurisdictions | Recommended |
| Monitor for evasion patterns (shell companies, TBML) | Critical |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to risk-ratings · SanctionsAI
+ \ No newline at end of file diff --git a/risk-ratings/north-korea/index.html b/risk-ratings/north-korea/index.html new file mode 100644 index 0000000..8b2f862 --- /dev/null +++ b/risk-ratings/north-korea/index.html @@ -0,0 +1,66 @@ + + + + + +North Korea (DPRK) is subject to comprehensive sanctions under the North Korea Sanctions and Policy Enhancement Act (NKSPEA). One of the most heavily sanctioned jurisdictions globally.
+The NKSPEA and Executive Order 13722 impose comprehensive sanctions on North Korea. The DPRK is notable for its state-sponsored crypto theft operations, with the Lazarus Group (designated under DPRK program) responsible for billions in stolen crypto. OFAC designated Tornado Cash and Blender.io specifically for facilitating DPRK money laundering.
+| Screening action | Priority |
|---|---|
| Screen all counterparties against OFAC SDN list | Critical |
| Enhanced due diligence on beneficial ownership | Critical |
| Screen transaction routes for sanctioned jurisdictions | Critical |
| Monitor for evasion patterns (shell companies, TBML) | Critical |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to risk-ratings · SanctionsAI
+ \ No newline at end of file diff --git a/risk-ratings/pakistan/index.html b/risk-ratings/pakistan/index.html new file mode 100644 index 0000000..393b334 --- /dev/null +++ b/risk-ratings/pakistan/index.html @@ -0,0 +1,66 @@ + + + + + +Pakistan is not comprehensively sanctioned but faces targeted designations related to proliferation, terrorism, and specific entities.
+Pakistan is not comprehensively sanctioned by OFAC. Targeted designations exist for entities involved in WMD proliferation and terrorism financing. Pakistan was on the FATF grey list (removed 2022). Most commercial transactions are permitted, but enhanced due diligence is recommended for defense, nuclear, and border-region counterparties.
+| Screening action | Priority |
|---|---|
| Screen all counterparties against OFAC SDN list | Standard |
| Enhanced due diligence on beneficial ownership | Standard |
| Screen transaction routes for sanctioned jurisdictions | Recommended |
| Monitor for evasion patterns (shell companies, TBML) | Recommended |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to risk-ratings · SanctionsAI
+ \ No newline at end of file diff --git a/risk-ratings/russia/index.html b/risk-ratings/russia/index.html new file mode 100644 index 0000000..c3ad07f --- /dev/null +++ b/risk-ratings/russia/index.html @@ -0,0 +1,66 @@ + + + + + +Russia is subject to extensive targeted sanctions following the 2022 invasion of Ukraine. Sanctions cover financial institutions, oligarchs, energy, technology, and military sectors.
+Russia is the most-sanctioned major economy. Following the February 2022 invasion of Ukraine, the US, EU, UK, and allies imposed sweeping sanctions under EO 14024. Major Russian banks, oligarchs, state-owned enterprises, and military suppliers are SDN-designated. The G7 oil price cap (effective December 2022) restricts Russian oil sales above $60/barrel.
+| Screening action | Priority |
|---|---|
| Screen all counterparties against OFAC SDN list | Critical |
| Enhanced due diligence on beneficial ownership | Critical |
| Screen transaction routes for sanctioned jurisdictions | Critical |
| Monitor for evasion patterns (shell companies, TBML) | Critical |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to risk-ratings · SanctionsAI
+ \ No newline at end of file diff --git a/risk-ratings/singapore/index.html b/risk-ratings/singapore/index.html new file mode 100644 index 0000000..24c17de --- /dev/null +++ b/risk-ratings/singapore/index.html @@ -0,0 +1,66 @@ + + + + + +Singapore is not subject to OFAC sanctions. It is a major financial hub with strong sanctions compliance framework. Low sanctions risk.
+Singapore is not subject to OFAC sanctions and maintains its own robust sanctions enforcement framework under the Monetary Authority of Singapore (MAS). As a major financial center, Singapore enforces UN and autonomous sanctions. Commercial transactions carry low sanctions risk, though Singapore is used as a transshipment point, requiring trade-based due diligence.
+| Screening action | Priority |
|---|---|
| Screen all counterparties against OFAC SDN list | Standard |
| Enhanced due diligence on beneficial ownership | Standard |
| Screen transaction routes for sanctioned jurisdictions | Recommended |
| Monitor for evasion patterns (shell companies, TBML) | Recommended |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to risk-ratings · SanctionsAI
+ \ No newline at end of file diff --git a/risk-ratings/syria/index.html b/risk-ratings/syria/index.html new file mode 100644 index 0000000..3edbb5a --- /dev/null +++ b/risk-ratings/syria/index.html @@ -0,0 +1,66 @@ + + + + + +Syria is subject to comprehensive US sanctions under the Syrian Civilian Protection Act and Executive Orders. All transactions with the Syrian government and most Syrian persons are prohibited.
+Syria is under comprehensive US sanctions via Executive Orders 13338, 13572, 13573, and 13606, plus the Caesar Syria Civilian Protection Act (2019). US persons cannot transact with the Syrian government, Central Bank of Syria, or designated individuals/entities. The Caesar Act extends secondary sanctions to non-US persons who support the Assad regime.
+| Screening action | Priority |
|---|---|
| Screen all counterparties against OFAC SDN list | Critical |
| Enhanced due diligence on beneficial ownership | Critical |
| Screen transaction routes for sanctioned jurisdictions | Critical |
| Monitor for evasion patterns (shell companies, TBML) | Critical |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to risk-ratings · SanctionsAI
+ \ No newline at end of file diff --git a/risk-ratings/turkey/index.html b/risk-ratings/turkey/index.html new file mode 100644 index 0000000..32527ac --- /dev/null +++ b/risk-ratings/turkey/index.html @@ -0,0 +1,66 @@ + + + + + +Turkey is not comprehensively sanctioned but faces targeted designations related to defense trade with Russia and human rights. CAATSA sanctions applied for S-400 purchase.
+Turkey is a NATO ally and not comprehensively sanctioned. The main sanctions exposure is CAATSA (Countering America's Adversaries Through Sanctions Act) sanctions imposed in December 2020 for Turkey's purchase of the Russian S-400 missile defense system. Individual Turkish officials have been designated for human rights concerns. Most commercial transactions with Turkey are permitted.
+| Screening action | Priority |
|---|---|
| Screen all counterparties against OFAC SDN list | Standard |
| Enhanced due diligence on beneficial ownership | Standard |
| Screen transaction routes for sanctioned jurisdictions | Recommended |
| Monitor for evasion patterns (shell companies, TBML) | Recommended |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to risk-ratings · SanctionsAI
+ \ No newline at end of file diff --git a/risk-ratings/uae/index.html b/risk-ratings/uae/index.html new file mode 100644 index 0000000..af74aa2 --- /dev/null +++ b/risk-ratings/uae/index.html @@ -0,0 +1,66 @@ + + + + + +The UAE is not sanctioned but is a high-risk jurisdiction for sanctions evasion due to its role as a financial hub serving Russia, Iran, and other sanctioned jurisdictions.
+The UAE itself is not sanctioned. However, OFAC and FinCEN have issued advisories warning that UAE-based entities (particularly in Dubai) are used by Russian, Iranian, and other sanctioned persons to evade sanctions. Compliance teams should apply enhanced due diligence to UAE counterparties, particularly those with connections to high-risk jurisdictions.
+| Screening action | Priority |
|---|---|
| Screen all counterparties against OFAC SDN list | Standard |
| Enhanced due diligence on beneficial ownership | Standard |
| Screen transaction routes for sanctioned jurisdictions | Recommended |
| Monitor for evasion patterns (shell companies, TBML) | Recommended |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker← Back to risk-ratings · SanctionsAI
+ \ No newline at end of file diff --git a/risk-ratings/venezuela/index.html b/risk-ratings/venezuela/index.html new file mode 100644 index 0000000..10c79b5 --- /dev/null +++ b/risk-ratings/venezuela/index.html @@ -0,0 +1,66 @@ + + + + + +Venezuela is subject to extensive targeted sanctions under EO 13884. The Maduro regime and associated entities are sanctioned, though some licenses exist for opposition-led activities.
+Venezuela is under extensive US sanctions following EO 13884 (2019), which blocks all property of the Maduro government. PDVSA (the state oil company) is designated. However, OFAC has issued general licenses for humanitarian transactions and for activities involving the democratically elected National Assembly. The sanctions landscape is complex and license-dependent.
+| Screening action | Priority |
|---|---|
| Screen all counterparties against OFAC SDN list | Critical |
| Enhanced due diligence on beneficial ownership | Recommended |
| Screen transaction routes for sanctioned jurisdictions | Recommended |
| Monitor for evasion patterns (shell companies, TBML) | Critical |
Check any wallet, name, or entity against OFAC, EU, UN sanctions lists in real time.
+Free wallet checker