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Decoding the 2026 OFAC Guidance on Sham Transactions & Sanctions Evasion
Analysis of the new OFAC "Functional Reality" standard. We discuss the December 2025 enforcement precedents and the 2026 advisory on sham transactions. Essential listening for Trade Compliance and KYC professionals.
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By PeteAnalysis of the new OFAC "Functional Reality" standard. We discuss the December 2025 enforcement precedents and the 2026 advisory on sham transactions. Essential listening for Trade Compliance and KYC professionals.