SAN009 · Sanctions

Complex Ownership Structures

Complex Ownership Structures use structural opacity itself as the evasion mechanism: deep layering, circular holdings, nominee tiers and clusters of secrecy-jurisdiction incorporations engineered so that no reader can trace ultimate control. The structure need not resolve to a *named* designated party to be a finding — the opacity is the risk.

The finding is a structural finding: how deep the layering runs, whether the ownership graph is circular, how many nominee tiers and secrecy jurisdictions appear, and how concentrated the network is around shared directors and addresses.

Risk indicators

Structural

• Layering depth ≥ 4–5
• Circular ownership loop
• Two or more nominee tiers

Network-Concentration

• Shared directors across nodes
• Shared registered addresses
• Multiple shell indicators

Jurisdiction

• Multiple secrecy jurisdictions (BVI, Cayman, Panama, Seychelles)

Counterparty

• Counterparties carrying sanctions exposure or adverse media

Investigation actions

1. Resolve every node and edge of the ownership structure.
2. Compute layering depth (longest path) and detect circularity (DFS cycle detection).
3. Count nominee tiers and secrecy jurisdictions.
4. Grade Ownership Structure from depth / circularity / nominee tiers.
5. Grade Network Concentration from shared directors, shared addresses, shell indicators.
6. Score jurisdiction and counterparty exposure.
7. Aggregate; escalate at or above the threshold.

Detection logic

1. Resolve every node and edge of the ownership structure. 2. Compute layering depth (longest path) and detect circularity (DFS cycle detection). 3. Count nominee tiers and secrecy jurisdictions. 4. Grade Ownership Structure from depth / circularity / nominee tiers. 5. Grade Network Concentration from shared directors, shared addresses, shell indicators. 6. Score jurisdiction and counterparty exposure. 7. Aggregate; escalate at or above the threshold.

Related typologies

Curated from fc-05-sanctions-exposure-analytics-toolkit/typologies/SAN009_Complex_Ownership_Structures.md