Jessica S. Carey, John P. Carlin, Roberto J. Gonzalez, Ian C. Richardson and Nicole Succar

Paul Weiss Discusses OFAC Guidance on “Sham Transactions” and Sanctions Evasion

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On March 31, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued a sanctions advisory providing guidance on sham transactions used to evade U.S. sanctions (the “Sanctions Advisory”).[1] The Sanctions Advisory identifies specific red …