Insights: Sanctions & Enforcement Analysis

Working notes on the measures that move fastest — OFAC, EU, and Swiss sanctions and enforcement actions. Analysis for the teams that have to act on them.

Serving a blocked institution: ICC vendors and four different licenses
Pegasus: a renamed supplier and an incomplete records search
Russian diesel under GL 135: shipment and payment review
Iran shipping checks and Samudra wind down
Russia GL 13S administrative transactions
DOJ fraud directives and company records
The end use behind the order: Iran’s new automotive and rail sanctions measures
The old payment route has closed: Cuba’s September 30 sanctions changes
The alert is not the answer: OFAC’s six steps from screening hit to decision
Sold on paper: sham transactions, and why a blocked interest does not leave when the owner does
Ownership and software origin certifications
Nineteen meetings and a dividend: the September Iran settlement’s company lesson
A sanctions program at fifty employees: what OFAC’s Framework actually asks for
After the wind-down deadline: OFAC’s August 2026 Iran general-license suspensions
One email in the wrong language: the Rice Lake OFAC settlement
A Warsaw Registration Is Not a Clean Bill of Health: OFAC's Third-Country Designations and What They Say About Your Screening
Foreign bribery and misleading deal reviewers
What Lukoil General License 131H allowed, and how OFAC replaced it
Zero percent U.S. content: de minimis and the Foreign Direct Product rules
Two outcomes after SDN removal: OFAC’s Hong Kong removals
Customs brokers and disguised reinspection payments
A European customer and the ultimate destination
A license arrived before the notice: OFAC’s DRC General License 2
Foreign-made products and trade compliance resources
The 50 Percent Rule: why a clean name screen is not a clean counterparty
You cannot do indirectly what you cannot do directly: the FTI Consulting settlement
A shorter list is not a smaller risk
"If a deal is too good to be true": the Adani Enterprises settlement
Facilitation: how U.S. persons in a non-U.S. group can trigger Iran sanctions restrictions
Cuba’s new sanctions program, and why "we are not a U.S. person" no longer ends the analysis
Primary and secondary sanctions: two architectures, one word
From guidance to a proposed program requirement: Treasury’s stablecoin proposal
Given up on paper only: OFAC’s sham transaction advisory
Consultant payments and a French-company resolution
A control you never test is a control you don’t have
A $3.77 million penalty against one person
The name on the invoice: the IMG Academy settlement
Sports hospitality and public procurement

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