2026-03-31 | 20260331_33

Guidance on Sham Transactions and Sanctions Evasion

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) issued a sanctions advisory to highlight risks associated with sham transactions used to evade sanctions. The document identifies specific factors to consider when evaluating whether property is the subject of a sham transaction. This guidance aims to assist entities in recognizing and avoiding activities that circumvent U.S. sanctions regimes.

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United States

Office of Foreign Assets Control

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Release Date

03/31/2026

Recent Actions Body

The U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) is issuing 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.