Sanction Violations

Sanction violations involve the direct or indirect engagement in transactions with individuals, entities, or jurisdictions that are subject to government-imposed sanctions. These restrictions are typically enforced by regulatory bodies such as the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), the United Nations, the European Union, and equivalent authorities in other jurisdictions.

Unlike export violations, which focus on the control of goods and technical data, sanction violations concern the status of the receiving party. A breach occurs when a subject facilitates, authorizes, or executes transactions that provide economic or material support to a sanctioned target—this includes sending payments, delivering services, providing access to infrastructure, or sharing non-controlled information with a restricted party.

Insiders may contribute to sanction violations by bypassing compliance checks, falsifying documentation, failing to screen third-party recipients, or deliberately concealing the sanctioned status of a partner or entity. Such conduct can occur knowingly or as a result of negligence, but in either case, it exposes the organization to serious legal and financial consequences.

Regulatory enforcement for sanctions breaches may result in significant penalties, asset freezes, criminal prosecution, and reputational damage. Organizations are required to maintain robust compliance programs to monitor and prevent insider-driven violations of international sanctions regimes.