OFAC Issues Advisory on Sham Transactions & Sanctions Evasion

On 31 March 2026, US Treasury’s Office of Foreign Assets Control (OFAC) issued an advisory to alert of sham transactions designed to evade sanctions and to identify red flags to consider when evaluating whether property may be the subject of a sham transaction. 

In this context, the OFAC Advisory explains that a sham transaction is an attempt by a blocked person to conceal, through use of a proxy or other intermediary, their continuing interest in property in order to evade sanctions.