What other tactics do people use to try to trick an automated screening tool or otherwise avoid
detection during sanctions payment screening? a) They may rearrange the data if they
know of a field that isn't routinely screened.
b) They may replace information with false data.
c) They may use red-flag phrases such as "No name," or "On behalf of...."
d) They may alter or abbreviate the sender or beneficiary's name, change the spelling to how it
sounds, add spaces within the name, or omit a middle name.
They may manually alter a message before sending it to the next financial institution.
What is Concealment? Sanctions evaders depend on concealment to avoid sanctions,
fines, and scandal. They may disguise the origin point of certain goods or funds. Or they may
hide the identity of the receiver of goods.
Sanctions evaders depend on concealment to avoid sanctions, fines, and scandal. They may
disguise the origin point of certain goods or funds. Or they may hide the identity of the receiver
of goods. Sanctions evaders have different ways to conceal the end user's identity or the
product's end use.
, a) The sanctions evader may use a straw buyer in another jurisdiction to buy the merchandise and
then complete a separate shipment or purchase after the export has occurred.
b) The evader may falsify the name of the purchaser or end user to avoid detection.
c) The evader may falsely state the purpose or intended use of the item in purchase orders,
transport documentation, and other documents related to the transaction.
For trade-based transactions, which include more documentation, concealment may take many
forms:
• Obscuring the origin of merchandise
• Obscuring the path of a vessel
• Transferring letters of credit
• Removing the names of financial institutions involved in the backing instrument, whether
through careful construction of alternate information or falsification of the documents
themselves
What is transshipment? Transshipment is the delivery of goods or containers to an
intermediate destination and then on to a further or final destination. It can also mean a change of
carrier or vessel.