A joint webinar hosted by IMTF and the Association of Certified Sanctions Specialists (ACSS), titled “A New Financial World Order: Sanctions Evasion on the Rise”, has shed light on how the nature of sanctions evasion has shifted — and what that means for those working in compliance.
According to IMTF, the core message was unambiguous: keeping up with sanctions is no longer a matter of checking names against a list. It requires an understanding of how global financial networks are structured and how they move.
IMTF recently talked about why sanctions evasion is no longer linear, but has become a networked process.
What was once a relatively contained challenge has become a far more intricate problem, one defined by interconnected actors, overlapping jurisdictions, and fragmented payment flows. This transformation demands a fundamental rethink of how risk is identified and managed.
From linear screening to networked risk
For years, sanctions compliance operated on a straightforward logic: find exposure to sanctioned entities or countries, and block it. That model is now out of step with reality. Evasion today runs through layered global networks in which transactions hop across multiple jurisdictions, ownership structures are deliberately obscured, and trade flows are broken up to conceal their true origin or destination.
Recent analyses have described this as “non-alignment 2.0” — a growing pattern of countries maintaining economic ties across geopolitical divides. The effect is an expanding patchwork of grey zones where compliance cannot be assessed through a single lens. Risk, in this environment, is not country-based. It is network-based.
A more sophisticated evasion landscape
What compounds the challenge is not just the scale of activity, but the increasing sophistication of the techniques being used. Intermediary jurisdictions have become central to evasion strategies, acting as commercial and financial bridges between sanctioned and non-sanctioned economies. Payment mechanisms are also evolving: whilst traditional currencies remain dominant, local currency settlements and digital assets are adding new layers of opacity to transactions.
The more fragmented the system becomes, the harder it is to see the full picture — and that is precisely where conventional detection methods begin to break down.
Why existing compliance frameworks are no longer sufficient
Many compliance frameworks continue to rely on a combination of country risk indicators, transaction monitoring, and list-based screening. These remain essential tools, but they are no longer adequate on their own. In a network-driven environment, risk rarely surfaces in a single transaction or counterparty. It emerges through patterns, relationships, and flows that only become visible when assessed collectively.
This creates a structural problem for financial institutions. Each organisation sees only a portion of the activity — a few pieces of a much larger puzzle. Without broader context, even well-designed controls can miss the overarching structure of an evasion scheme.
Moving towards corridor thinking
Adapting to this new reality means moving beyond static, country-based assessments towards a more dynamic way of thinking about risk. Rather than focusing solely on where a transaction starts or ends, compliance teams must pay greater attention to how it moves — through which trade routes, financial flows, and intermediary relationships.
This corridor-based approach, which looks at how transactions travel across jurisdictions and through intermediaries, helps institutions identify inconsistencies, unusual patterns, and indirect exposure that would otherwise go undetected. It reflects the way sanctions evasion actually works today: not in isolation, but across interconnected systems.
What effective detection looks like today
Addressing this level of complexity requires more than incremental adjustments. It calls for a more integrated and intelligent approach to detection. Among the leading practices now emerging are network analysis to surface relationships between entities and counterparties; comprehensive screening that covers all relevant stakeholders — from senders and recipients to insurers, vessel crews, agents, ports, and vendors; cross-referencing against Dual Use Goods lists, BIS registers, commodity lists, and internal watchlists; monitoring for gaps in AIS (Automatic Identification System) vessel records; integrating vessel tracking data; identifying falsified trade documents and suspicious code names; scrutinising new supply routes involving unknown companies or unusual payments; flagging ports located in close proximity to sanctioned countries; and where possible, comparing satellite imagery against AIS logs and vessel positions to verify accuracy.
According to ITMF, Behavioural monitoring to track evolving patterns over time, the integration of multiple data sources spanning financial transactions, trade intelligence, and maritime data, and near real-time processing to close detection gaps are also becoming standard features of robust compliance programmes. The objective is not simply to gather more data, but to connect it in ways that reveal what would otherwise remain hidden.
The missing piece: collaboration across the ecosystem
Perhaps the clearest takeaway from the webinar is that no single institution can fully address this challenge on its own. Sanctions evasion is inherently global in scale, but detection remains largely fragmented. Each institution operates within its own perimeter, with limited visibility beyond it — and sophisticated actors are increasingly adept at exploiting that blind spot, said IMTF.
Greater effectiveness will require a broader shift: towards interoperability, better data standardisation, and stronger collaboration across the financial ecosystem. In a networked environment, isolated detection is simply no longer enough.
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