Sanctioned / OFAC SDN
Shell / Nominee Entity
Transit / Logistic Hub
Refinery / Commercial Off-Taker
Artisanal Concession
Under US Department of the Treasury (OFAC), EU, and UK sanctions regimes, any entity owned 50 percent or more in the aggregate, directly or indirectly, by one or more blocked persons is itself considered blocked by operation of law—even if not specifically named on sanctions lists.
As documented in investigative exposés on conflict gold, illicit networks systematically circumvent designations by inserting nominee directors, shifting corporate registrations to tax havens or free zones, and transshipping bullion through border hubs to mask provenance before melting at certified commercial refineries.
This auditor evaluates circular transit routing, high-risk jurisdiction hops, and sudden post-designation trade volume spikes to highlight compliance vulnerabilities.