Tracing financial flows and sanctions evasion in OSINT

Block

07 · Corporate, Financial & Legal

Topic

Financial Flows & Sanctions Evasion

Tools

OpenSanctions · ICIJ OffshoreLeaks · OpenCorporates · Sayari

Difficulty

Advanced

Prerequisites

Satellite imagery change detection: Sentinel and Landsat.

Corporate registries and sanctions databases reveal where money went

Every transfer of value leaves a record somewhere. The challenge is knowing which registries hold which fragment and how to connect them into a chain that meets evidentiary standard, from sanctions lists and beneficial ownership registers to the leak databases that expose what official filings conceal.

Sanctions evasion surfaces in corporate investigations, procurement fraud, human rights reporting and conflict finance. The registries here are used by compliance teams at major financial institutions, international prosecutors and investigative desks at ICIJ and OCCRP; access is free or low-cost. The central concept is beneficial ownership: a designated entity uses intermediaries including shell companies, nominee directors and trusts to hold assets at a distance.

Your task is to reconstruct the ownership chain behind each intermediary until you reach a natural person or a named entity on a sanctions list.

In the field

The ICIJ's Pandora Papers investigation traced financial flows from sanctioned individuals through a network of offshore trusts and shell companies set up by 14 offshore service providers across at least 38 jurisdictions, showing how assets stayed accessible to designated persons via ownership arrangements exploiting cross-jurisdictional disclosure gaps.

Beneficial ownership tracing. Cross-referencing leaked incorporation records against OFAC and EU lists identified trusts and companies linked to sanctioned individuals whose assets had not been frozen.
Corporate registry cross-referencing. Matching nominee director names across OpenCorporates and Panama Papers data established shared infrastructure across nominally unrelated vehicles.
Sanctions list screening. Screening identified beneficial owners against OpenSanctions confirmed designations under multiple regimes not visible in any single national list.

ICIJ · Pandora Papers · October 2021; OCCRP partner investigations, 2021–2022

Learning outcomes

By the end of this tutorial you will be able to:

Screen entities against multiple sanctions regimes simultaneously using OpenSanctions
Trace beneficial ownership chains through registries, nominee arrangements and offshore structures
Identify shared nominee and corporate infrastructure across shell companies using ICIJ OffshoreLeaks and OpenCorporates
Assess jurisdictional disclosure gaps and identify the authoritative registry for each entity
Document a financial flow chain to evidentiary standard with sourced, confidence-tiered links

The rest of this tutorial is for Signal subscribers.

What remains: the decision framework, the tool configuration, the failure modes, and the evidentiary standard required to use the finding defensibly. Signal is €90 a year, or €9 a month. Students, €49 a year.

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Financial flows and sanctions evasion: investigator's guide

Corporate registries and sanctions databases reveal where money went

Learning outcomes

The rest of this tutorial is for Signal subscribers.

A Signal subscription gives you:

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