On March 31, 2026, the OFAC issued a sanctions advisory to highlight sanctions risks arising from sham transactions used to evade sanctions and to identify factors to consider when evaluating whether property may be the subject of a sham transaction. Sham transactions occur when blocked individuals use intermediaries to falsely give up property to evade sanctions while still retaining an interest in it.
The Advisory provides red flags that may indicate sham transactions, including
Commercially unreasonable transactions;
Transfer to family members or close associates;
Unclear purpose of transfer;
Unduly complex corporate structures involving higher-risk jurisdictions;
Continued involvement of a blocked person;
Transfer near the time of designation; and
Evasive responses regarding a blocked person’s involvement.
The full sanctions advisory can be found here.