OFAC issues an advisory warning that sanctioned individuals are using ‘sham transactions’, proxies, trusts, and shell companies to conceal ongoing property ownership

The advisory highlights key red flags, including non-commercial transfers, opaque ownership structures, involvement of close associates, continued control by sanctioned persons, and transactions timed around designations, and stresses that firms must apply a risk-based approach, enhanced due diligence, and ongoing monitoring to detect evasion. It reinforces that any property in which a sanctioned person retains an interest must remain…