TBML010 · TBML

Sanctions Evasion Through Trade

Sanctions Evasion Through Trade uses ordinary-looking trade to move value or goods to or from a sanctioned party or jurisdiction. The trade documents describe a legitimate transaction, but a party to it — or the jurisdiction it touches — is subject to sanctions. Trade becomes the vehicle for maintaining a commercial relationship that direct payment or name screening would block. This is the most severe of the TBML typologies.

It is used to:

• Move value or goods to or from a sanctioned interest under cover of trade
• Maintain a commercial relationship a sanctions programme prohibits
• Route sanctioned trade through intermediaries and free zones
• Conceal a designated party behind a clean-screening counterparty
• Support state-linked or proliferation trade

Risk narrative

A customer trades a commodity with a counterparty that is on a sanctions list, and/or through a jurisdiction subject to sanctions. The paperwork is consistent with an ordinary trade, but the exposure is direct: a designated party, a sanctioned origin, and a high-risk corridor. Where the counterparty is a shell and the parties share ownership, the trade is a sanctions- evasion channel — and the finding escalates to Critical.

Risk indicators

Risk

• Sanctioned Party
• Sanctioned Jurisdiction
• High Risk Jurisdiction
• High Risk Corridor
• Shell Company Structure
• Related Party Trading

Investigation actions

1. Screen the parties and jurisdictions against sanctions lists (UN, OFAC, OFSI, EU).
2. Resolve ownership and control; apply the 50% rule where relevant.
3. Consider a freeze pending review.
4. Assess whether intermediaries or free zones mask the sanctioned exposure.
5. Escalate as a priority investigation.

Use cases

• Sanctions Evasion · Trade Based Money Laundering (TBML)
• Proliferation Financing · State-Linked Trade
• Related Party Value Transfer · Shell Company Abuse

Related typologies

Curated from fc-04-tbml-analytics-toolkit/typologies/TBML010/TBML010_Sanctions_Evasion_Through_Trade.md