SAN006 · Sanctions

Trade Based Sanctions Evasion

Trade-Based Sanctions Evasion moves value or prohibited goods across a sanctioned boundary by manipulating the trade transaction itself — mispricing an invoice, or misdescribing the goods so that a controlled item travels under an innocuous label. The transaction is the instrument of evasion.

The finding is a trade-anomaly finding: an abnormal deviation between declared and benchmark price, and/or a mismatch between declared and actual goods, weighted against the destination, the counterparty and any ownership link to a designated party.

Risk indicators

Trade-Anomaly

• Large price deviation from benchmark (over/under-pricing)
• Goods misdescription (declared ≠ actual)
• High-value cargo under generic descriptions

Jurisdiction

• Sanctioned destination

Counterparty

• Counterparty sanctions exposure or adverse media

Ownership

• Trading party owned by / linked to a designated party

Investigation actions

1. Resolve the trade, its parties and counterparties.
2. Compare declared unit price against benchmark; grade the deviation.
3. Compare declared against actual goods for misdescription.
4. Score jurisdiction exposure for the destination.
5. Score counterparty exposure and any ownership link to a designated party.
6. Aggregate; escalate at or above the threshold.

Detection logic

1. Resolve the trade, its parties and counterparties. 2. Compare declared unit price against benchmark; grade the deviation. 3. Compare declared against actual goods for misdescription. 4. Score jurisdiction exposure for the destination. 5. Score counterparty exposure and any ownership link to a designated party. 6. Aggregate; escalate at or above the threshold.

Related typologies

Curated from fc-05-sanctions-exposure-analytics-toolkit/typologies/SAN006_Trade_Based_Sanctions_Evasion.md