By · · last updated 2026-08-08
The documented evasion patterns: shell companies, mixers, geographic routing, and structering. What enforcement cases show and how screening closes each gap.
Sanctions evasion is not one technique - it is a set of patterns, and the enforcement record shows the same shapes repeating.
A blocked person owns 50%+ of an entity that never appears on the list. Name screening misses it; the 50% rule catches it.
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Routing through Tornado Cash, Blender, or Sinbad to launder the destination. The designated mixer addresses are on the wallet list - see the mixer record.
Settling through banks, exchanges, or addresses in sanctioned jurisdictions. Geography is the third screening surface - Bitfinex, BitPay, and Ripple all settled on it.
Splitting payments to stay under thresholds. Aggregation controls catch the pattern - the structuring scenario shows why.
Every pattern fails against the same stack: wallet + name + jurisdiction screening on every payment, aggregation, and an audit trail.
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