https://www.mondaq.com/unitedstates/export-controls-trade-investment-sanctions/1770958/ofac-issues-sanctions-advisory-on-sham-transactions-identifies-red-flags
OFAC Issues Sanctions Advisory On Sham Transactions, Identifies Red Flags - Export Controls & Trade...
On March 31, 2026, OFAC published a Sanctions Advisory that highlights compliance risks arising from sham transactions used to evade sanctions.
advisory on sham transactions