CSS Study Guide 2026

Transshipment as a sanctions evasion technique involves routing goods through a third, non-sanctioned country (a 'transit hub') to obscure that they originated from or are destined for a sanctioned country.

A specific license is an individual written authorization from OFAC permitting a particular person or entity to engage in a transaction that would otherwise be prohibited.

FATF has published guidance and trade-based money laundering (TBML) risk indicators to help financial institutions and regulators identify suspicious trade transactions that may involve sanctions evasion, money laundering, or terrorist financing.

OFAC has published specific guidance for the insurance industry (including brokers, agents, and underwriters) outlining how sanctions obligations apply to insurance products such as policies, claims, and reinsurance.

Under the 50 Percent Rule, any entity owned 50% or more by one or more SDN-listed parties is treated as sanctioned itself, expanding the universe of parties covered by both primary and secondary sanctions.

The purpose of reporting obligations in sanctions compliance is to ensure transparency and provide regulatory authorities with crucial information regarding transactions or individuals potentially linked to sanctioned entities. This enables authorities to monitor compliance, investigate suspicious activities, and take necessary enforcement actions to uphold the integrity of the sanctions regime.