News & Analysis as of

Evasion

Holland & Knight LLP

AI and Cyber-Enabled Tools Are Changing Sanctions Compliance Risks: Are You Prepared?

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Artificial intelligence (AI) is reshaping the global economy and changing the way business is done, with dramatic implications for how companies manage compliance risk. Cybercriminals and other bad actors have new AI and...more

WilmerHale

50 Percent is Not Enough: OFAC’s New Guidance on Sham Transactions and Sanctions Evasion

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On March 31, 2026, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued a sanctions advisory titled Guidance on Sham Transactions and Sanctions Evasion (Guidance). ...more

Latham & Watkins LLP

FinCEN Proposes Regulations to Implement Whistleblower Program: 4 Key Takeaways

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The program provides new financial incentives for whistleblowers to report information about potential violations of money laundering and sanctions laws....more

Fenwick & West LLP

OFAC Issues Guidance on Sham Transactions and Sanctions Evasion

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OFAC issued the advisory to explain that a sham transaction designed to evade sanctions does not extinguish a sanctioned person’s interest in property. As a result, OFAC continues to impose blocking sanctions and prohibit...more

Husch Blackwell LLP

OFAC Issues Guidance on Sham Transactions and Sanctions Evasion

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On March 31, 2026, the Office of Foreign Assets Control (“OFAC”) issued an advisory (the “Advisory”) regarding sham transactions and their use in evading US sanctions. OFAC described sham transactions as occurring when...more

Mayer Brown

UK Weekly Sanctions Update - Week of March 16, 2026

Mayer Brown on

In this weekly update, we summarise the most notable updates in the UK sanctions world. Russia Sanctions - UK Government amends one entry on the UK sanctions list under the Russia sanctions regime: On March 12, 2026, the FCDO...more

Holland & Knight LLP

Maritime Finance: A Look Back at 2025 and Trends to Watch in 2026

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The maritime finance industry saw significant change in 2025, including the shipping sector becoming a key target of sanctions policymakers, evolving regulatory action and lending trends, and the increased role of private...more

American Conference Institute (ACI)

[Event] 10th Annual Canadian Forum on Global Economic Sanctions - February 25th - 26th, Toronto, ON, Canada

Canadian Institute's 10th Annual Canadian Forum on Global Economic Sanctions brings together leading regulators, enforcement officials, compliance professionals, and top decision-makers....more

Hughes Hubbard & Reed LLP

EU Sanctions in a Snap: Developments in Sanctions - November 2025

Hughes Hubbard’s “Sanctions in a Snap” provides a clear and concise summary of recent developments from the United States' Office of Foreign Assets Control (OFAC) and the European Union and its Member States. The U.S. edition...more

Troutman Pepper Locke

Tariff Evasion Enforcement Heats Up: DOJ’s Latest Action

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On November 17, 2025, the U.S. Department of Justice (DOJ) announced criminal charges against a company and three individuals in connection with a large-scale duty and tariff evasion scheme. As alleged, the charged defendants...more

American Conference Institute (ACI)

[Event] 15th Annual New York Forum on Economic Sanctions - December 3rd - 4th, New York, NY

How are multinationals managing sanctions and export control risks in today’s challenging business environment? Attend ACI’s 15th Annual New York Forum on Economic Sanctions to receive the critical information you need to...more

Benesch

DOJ’s New Trade Fraud Task Force Raises Criminal Exposure for Importers

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The Department of Justice (DOJ) has identified trade and customs fraud as among a few  prioritized areas for agency investigation and prosecution. The Department announced a new inter-agency Trade Fraud Task Force on August...more

The Volkov Law Group

DOJ Settles Two False Claims Act Cases for Evasion of Customs Duties

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The Trump Justice Department has fully embraced the False Claims Act, stretching its use to include trade enforcement. DOJ recognizes the power of the FCA, the issues at stake, and the ability to extract large settlements....more

Parker Poe Adams & Bernstein LLP

Key Compliance Takeaways for Companies as Trump Administration and DOJ Focus on Tariff Fraud, Evasion

During the many months of President Donald Trump imposing, or threatening to impose, tariffs on some of the country’s largest trading partners — both friend and foe — some foreign suppliers have implemented plans to evade the...more

The Volkov Law Group

Episode 379 — Update on False Claims Act and Customs Fraud

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The Trump Administration intends to leave a strong enforcement mark on fraud and trade enforcement. DOJ is linking together trade enforcement and False Claims Act cases in an unprecedented manner that will open up new...more

Holland & Knight LLP

Importers Beware: Signals Point to Significant Enforcement Risks for Tariff Evasion

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As importers await outcomes from the Trump Administration's trade negotiations, a series of newly imposed tariffs continues to impact a broad spectrum of imported products and related supply chains. Businesses are currently...more

The Volkov Law Group

The False Claims Act and Trade Enforcement (Part I of II)

The Volkov Law Group on

The Trump Administration intends to leave a strong enforcement mark on fraud and trade enforcement. DOJ is linking together trade enforcement and False Claims Act cases in an unprecedented manner that will open up new...more

Mintz

Dodging Duties: The Ninth Circuit Affirms an Expansive Application of the False Claims Act Consistent with Trump Administration...

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On June 23, 2025, the United States Court of Appeals for the Ninth Circuit affirmed a district court judgment in a case in which the jury found the defendant knowingly made false statements on customs forms to avoid paying...more

Holland & Knight LLP

FinCEN Advisory Highlights Iran Sanctions Evasion Red Flags

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The U.S. Department of the Treasury's (Treasury) Financial Crimes Enforcement Network (FinCEN), published the FinCEN Advisory on the Iranian Regime's Illicit Oil Smuggling Activities, Shadow Banking Networks, and Weapons...more

BakerHostetler

Weekly Blockchain Blog - June 2025 #3

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French Bank Launches USD Stablecoin, US Fintech Expands Stablecoin Reach - The crypto assets division of a major French multinational bank and financial services company (Bank) recently announced the launch of its U.S....more

Warner Norcross + Judd

DOJ Announces “New Page” in White Collar and Corporate Enforcement

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Matthew Galeotti, head of the Department of Justice’s (DOJ) Criminal Division announced in May that DOJ “is turning a new page on white-collar and corporate enforcement.” The same day, the Criminal Division circulated four...more

Womble Bond Dickinson

Bridging the Gap: Applying Anti-Money Laundering Techniques and AI to Combat Tariff Evasion

Womble Bond Dickinson on

In today's global economy, characterized by complex supply chains and escalating trade tensions, tariff evasion has emerged as a significant threat to economic stability, fair competition, and government revenue. Traditional...more

BakerHostetler

Should You Consider a Voluntary Self-Disclosure for a Tariff Violation?

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Tariff evasion techniques such as transshipping goods through third countries, underreporting the value of goods, and mislabeling goods as other items subject to lower tariff rates have resulted in hundreds of billions of...more

BakerHostetler

Weekly Blockchain Blog - December 2024

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New Crypto Products Announced by Financial Services Firms, Exchanges, DEXs - A major U.S. cryptocurrency exchange recently announced that it has integrated a major mobile payments application into its Onramp tool to enable...more

Venable LLP

OFAC Issues Sanctions Compliance Guidance and Scenarios for U.S. and International Maritime Industry

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On October 31, 2024, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) issued scenario-based guidance specific to the maritime shipping industry....more

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