Beyond list screening
Modern evasion mixes clean entities, opaque ownership, and logistics tricks. Detecting it
requires contextual signals and collaborative playbooks.
Signals to add
- Maritime: dark activity patterns, spoofed AIS, unusual loitering.
- Trade: HS‑code risk, route anomalies, free‑zone hops.
- Ownership: recent shell creation, nominee directors, trust chains.
- Payments: circular flows among “clean” counterparties.
What to change in your program
- Include logistics and routing data in sanctions case reviews.
- Define when clean counterparty + dirty context = escalate.
- Run retrospective sweeps after regime updates.
Goal: move from name‑matching to behavior‑matching—that’s where most
evasion lives.