December 9, 2024 ZW confirmed
Kamlesh Pattni's global gold smuggling network: 28 designations
The archetype of the corruption network only a graph deciphers. On December 9, 2024, OFAC sanctioned 28 individuals and businesses of a global gold smuggling and laundering network based in Zimbabwe, under E.O. 13818. Per Treasury, the network led by Kamlesh Pattni facilitated illicit activities by bribing officials, deploying trusted supporters to mask ownership, and weaving a global web of businesses. It is the literal description of why a graph is indispensable: not 28 separate names, but a structure of front men and shell companies designed to hide a central actor. The Sentry documents how targeted Magnitsky sanctions supported democracy in Africa.
February 20, 2025 VE confirmed
Tren de Aragua designated a foreign terrorist organization
The component showing how terrorist designation amplifies risk beyond individuals. On February 20, 2025, the State Department designated Tren de Aragua (TdA) —a gang originating in a Venezuelan prison— as an FTO and SDGT, consistent with E.O. 14157. Treasury had already sanctioned it as a transnational criminal organization on July 11, 2024. The designation enables new sanctions, law-enforcement and immigration actions: the administration invoked the Alien Enemies Act to remove alleged members to El Salvador (under legal challenge). Its leader, Héctor Guerrero Flores, was charged in the expanded Maduro indictment. Since January 2025 the DOJ has indicted over 260 members via Joint Task Force Vulcan.
July 25, 2025 VE confirmed
Cartel de los Soles: OFAC designates the Maduro regime's leadership as a global terrorist
The designation blurring the line between state and criminal network —the extreme case of PEP risk. On July 25, 2025, OFAC designated the Cartel de los Soles as a Specially Designated Global Terrorist (SDGT). Per Treasury, it is a Venezuela-based criminal group headed by Nicolás Maduro Moros and other senior officials who, per the designation, corrupted state institutions —military, intelligence, legislature and judiciary— to assist narcotics trafficking into the U.S., providing material support to Tren de Aragua and the Sinaloa Cartel. The action triggered an international cascade: Ecuador, Paraguay, Argentina, Peru and the Dominican Republic also designated the cartel. When the state's leadership is labeled a criminal network, every person and company with a regime nexus inherits maximum exposure.
March 31, 2025 US confirmed
Global Magnitsky: 70 designations for corruption and abuses in 2024, the instrument reaching PEPs across the region
The legal framework structuring the tracker. The Global Magnitsky Human Rights Accountability Act, implemented by Executive Order 13818, lets OFAC block the property of persons involved in serious human rights abuses or corruption. Per the 2024 annual report to Congress (March 2025), OFAC imposed E.O. 13818 sanctions against 70 individuals and entities that year. In Latin America it has clear precedents: OFAC sanctioned a former Guatemalan official (Alberto Pimentel Mata) for mining corruption. The designation is public, reasoned and reversible —OFAC removes names when conduct changes— so monitoring must be continuous.
November 6, 2025 US confirmed
The UN consolidated list: 727 persons and the multilateral layer screening must cross alongside OFAC, EU and UK
The component completing the map of sanctions sources a serious PEP graph must integrate. As of November 6, 2025, the UN Security Council Consolidated List included 727 individuals and 273 entities subject to sanctions. Since 1966, the Security Council has established over 30 sanctions regimes —active against actors in the Central African Republic, DR Congo, Libya, Mali, North Korea, Somalia, Sudan, South Sudan, Yemen, among others, plus ISIS/Al-Qaeda and the Taliban—, applicable to all member states. Unlike OFAC's unilateral designations, UN ones require Council consensus, making them harder to adopt but universally binding: if a person is on the UN list, regulated businesses must reject them as a client in any jurisdiction. A complete PEP graph must cross OFAC, the EU, the UK and the UN, because each source has a distinct perimeter. The tracker records the list's existence and composition; geopolitical dynamics are attributed to their sources.
January 29, 2026 GB confirmed
UK: OFSI's autonomous anti-corruption regime and why PEP screening cannot rely on OFAC alone
The case proving sanctions lists are multiple and must be cross-referenced. After Brexit, the UK operates under the Sanctions and Anti-Money Laundering Act 2018 (SAMLA), which lets it design autonomous sanctions policies, administered by HM Treasury's Office of Financial Sanctions Implementation (OFSI). The UK has its own Global Anti-Corruption Regime (in force since April 2021, complementing the Global Human Rights Regime of July 2020), with designations distinct from the U.S. ones. UK sanctions apply to all persons and organizations operating in the UK, to UK nationals abroad and to overseas subsidiaries controlled by UK businesses. In January 2026, OFSI confirmed it will proceed with civil-enforcement reforms, with cumulative discounts (up to 30% for voluntary disclosure, 20% additional) and a higher penalty ceiling; it also explores aligning with the U.S. and EU by adopting the '50% or more' ownership rule. OFSI's consolidated list was retired on January 28, 2026. A serious PEP graph must cross OFAC, the UK Sanctions List and EU lists.
November 27, 2024 SV confirmed
El Salvador: the Engel List and the reputational layer —the flagged official without asset blocking
The case introducing an exposure layer distinct from the SDN sanction: the reputational one. The Engel List (formally Section 353), compiled by the State Department, identifies corrupt and undemocratic actors in Central America, imposing visa restrictions —but, unlike OFAC's SDN list, without asset blocking. Three officials of Nayib Bukele's government have been flagged, and other Salvadoran cases are processed via the Magnitsky Act. The distinction is key for diligence: a PEP may not be on the asset-blocking list but may be on a reputational visa list, which is a risk signal of equal importance for screening, though of distinct legal nature. The graph must integrate both layers: the blocking one (OFAC) and the reputational one (Engel).
January 16, 2025 SD confirmed
Sudan: both civil-war leaders sanctioned —Hemedti (RSF) and Burhan (SAF)— with a genocide determination and a UAE business network
The case showing the symmetric designation of both factions of a conflict and their transnational corporate financing. In January 2025, OFAC designated the two top leaders of Sudan's civil war under Executive Order 14098: on January 7, Mohammad Hamdan Daglo Mousa ('Hemedti'), commander of the Rapid Support Forces (RSF), and on January 16, Abdel Fattah Al-Burhan, leader of the Sudanese Armed Forces (SAF). In January 2025 the State Department determined that RSF members and allied militias committed genocide in Darfur; under Burhan's leadership, SAF tactics included indiscriminate bombing of civilian infrastructure. Alongside Hemedti, OFAC sanctioned Capital Tap Holding L.L.C., a UAE-based company managing about 50 companies in ten countries that, per Treasury, provided the RSF with money and military equipment, along with its owner Abu Dharr. The war has displaced over 12 million people. In April 2026 OFAC sanctioned a network recruiting former Colombian military personnel to fight for the RSF. For diligence, Sudan demonstrates that a conflict is financed through corporate networks in third countries: exposure is not in Khartoum, but in a Dubai holding with presence in ten jurisdictions.
March 10, 2026 RU confirmed
Russian offshore oligarchs, Navalny-related designations and evasion networks
The consolidated picture of Russian PEP risk with offshore connection. Between 2024 and early 2026, the U.S., EU and UK coordinated designations of numerous Russian individuals with offshore connections, integrating OFAC, the EU External Action Service, HM Treasury and the ICIJ database. The lines of action: expanded sectoral sanctions; focus on evasion networks via third-country facilitators —UAE, Türkiye, Eurasia— with shell companies and crypto assets; designations linked to Alexei Navalny's imprisonment and death. The Russian oligarch rarely appears directly; their exposure lives in offshore structures and front men, exactly the network a graph reveals.
April 23, 2026 EU confirmed
EU, 20th package: 120 new designations against Russia, with oligarchs and the evasion network as PEP target
The package showing the industrial scale of Russian PEP sanctioning. On April 23, 2026, the EU Council adopted its 20th package against Russia, with 120 new designations (37 individuals and 83 entities), the largest in two years. Beyond the shadow fleet and energy, the individual designations include oligarchs, those responsible for the abduction of children from Ukraine, propagandists and those responsible for looting heritage; and 16 third-country entities (China, UAE, Uzbekistan, Kazakhstan, Belarus) for supplying dual-use goods. Given effect via Regulations (EU) 2026/506, 2026/511 and 2026/509, after Hungary and Slovakia withdrew their veto. Each package expands the universe of Russian PEPs and their facilitators (distinct from vessel tracking).
August 6, 2024 PY confirmed
Cartes (Paraguay): the PEP→company cross-reference in pure form
The textbook example of why the relationship graph matters: the sanction does not stop at the person, it reaches their companies. OFAC sanctioned former president Horacio Manuel Cartes Jara and then-vice-president Hugo Adalberto Velázquez Moreno for corruption, under E.O. 13818. In the same designation it included companies owned or controlled by Cartes: Tabacos USA Inc., Bebidas USA Inc., Dominicana Acquisition S.A. and Frigorifico Chajha S.A.E. In August 2024 it reinforced the network by designating Tabacalera del Este S.A. (Tabesa). A seemingly clean corporate client may be under the control of a sanctioned PEP; without the person→beneficial-owner→company cross-reference, diligence misses it.
October 31, 2025 PY confirmed
OFAC delists Cartes from the SDN list: the full cycle of reversible designation
The cycle's close demonstrating a designation is not permanent. In October 2025, OFAC removed former Paraguayan president Horacio Manuel Cartes Jara and several affiliated companies from the SDN list, reversing measures in place for nearly three years under the Global Magnitsky Act. The contrast with his designation (August 2024, reinforced by adding Tabesa) is the methodological lesson: SDN designation is reversible. The same period saw another reversal: in April 2025 the administration terminated E.O. 13818 sanctions against a Hungarian official designated in January 2025, with the Secretary of State declaring their 'continued designation was inconsistent with foreign-policy interests'. A PEP's status can change for foreign-policy reasons, not just conduct.
June 13, 2026 PA confirmed
The Martinelli node in the graph: from the ex-president to his sanctioned sons, the family network diligence must see whole
The case illustrating the graph's value over a flat list. Diálogo Ciudadano's Mapa del Poder contains former president Ricardo Alberto Martinelli Berrocal (president of Panama 2009-2014) and, connected by verified family relationship, his sons Ricardo Alberto and Luis Enrique Martinelli Linares, central actors in the Panamanian chapter of the Odebrecht case: they pleaded guilty in the U.S. to money laundering for channeling bribes from the Brazilian builder. Martinelli himself was barred from entering the U.S. in January 2023 and convicted in Panama in July 2023 to over a decade in prison for laundering (New Business case), before taking asylum in Nicaragua's embassy. A flat list flags each individual separately; the graph shows this is a single family network with shared exposure —the relatives-and-close-associates (RCA) blind spot. This event anchors the tracker in its moat: the node→relationship→exposure cross-reference.
December 19, 2025 PA confirmed
Clinton List expands to Panamanian businessmen: the Carretero brothers and the close-associate blind spot
The textbook case of close-associate (RCA) risk crossing borders. On December 19, 2025, OFAC expanded the SDN ('Clinton List') with seven associates of Venezuelan president Nicolás Maduro. Among those designated are the Panamanian businessmen Roberto Carretero Napolitano and Vicente Luis Carretero Napolitano, brothers of Ramón Carretero Napolitano —previously sanctioned— whom The New York Times describes as the main intermediary for oil traded between Venezuela and Cuba, with operations approaching $500 million via his company Shineful Energy since July 2025. The designation came the same day as Carlos Malpica Flores, former PDVSA vice-president and nephew of the first lady. A Panamanian national can be designated for a role in a third country's network, and exposure transmits through family and corporate ties.
February 26, 2026 NI confirmed
Nicaragua: OFAC sanctions five senior officials sustaining the Murillo-Ortega dictatorship
The case showing a regime designated by functional layers —finance, communications, military. On February 26, 2026, OFAC sanctioned five officials leading the principal financial, communications and military agencies: the Director and Deputy Director of the Financial Analysis Unit (retired Major General Denis Membreño Rivas and former commissioner Aldo Martín Sáenz Ulloa), the Minister of Labor, the Deputy Director of the Nicaraguan Telecommunications Institute, and the head of Military Intelligence. Designated under E.O. 13851 (as amended by 14088). The program is one of targeted designations —not a comprehensive embargo—, coordinated with Canada, the UK and the EU. The regime is sanctioned by function, and each designation adds a node to the exposure network.
March 21, 2026 NI confirmed
The Ortega-Murillo family financial network: the textbook PEP laundering through children and companies
The clearest Ibero-American example of the RCA blind spot. OFAC's Nicaragua designations have reached the ruling family: Rafael Antonio Ortega Murillo, son of president Daniel Ortega, was designated for laundering, described by Treasury as 'the key money manager behind the Ortega family's illicit financial schemes', along with companies he controls —including Distribuidora Nicaragüense de Petróleo S.A. (DNP), also tied to vice-president and first lady Rosario Murillo—, used for enrichment via non-competitive contracts. The PEP's money is not in their name, but in their children's and their companies'.
December 17, 2025 MX confirmed
Mexico: from cartel to formal banking — how Sinaloa and CJNG transmit exposure to financial institutions
The case showing exposure transmission from organized crime to formal banking. Throughout 2025, OFAC intensified designations against Mexico's Sinaloa and CJNG cartels and, tellingly, against the financial vehicles connecting them to the formal system. In June 2025, via PATRIOT Act section 311, Treasury flagged three institutions —CIBanco, Intercam Banco and brokerage Vector— as of 'primary money laundering concern'. The designations cover bulk-cash laundering, fuel theft ('huachicol'), the 'Chapitos' faction and even a Florida school that received payments from sanctioned parties. A seemingly legitimate bank can be the bridge between a cartel and the system: the graph connecting cartel→front→bank is what makes it visible.
July 24, 2025 MM confirmed
Myanmar: the military junta sanctioned to its top —Min Aung Hlaing— and the selective delisting showing sanctions as a dynamic instrument
The Asian case combining the designation of an entire military regime with the mechanics of selective reversibility. After the February 1, 2021 coup in which the Tatmadaw deposed Aung San Suu Kyi's elected government, the U.S. reactivated and expanded its program under Executive Order 14014. Key designations reached the military leadership: commander-in-chief Min Aung Hlaing and deputy commander Soe Win —the former for his role commanding forces responsible for serious abuses, including the 2017 Rakhine operation that caused over 500,000 Rohingya to flee—, plus State Administration Council members and conglomerates like Myanma Economic Holdings. The U.S. concluded the Burmese military committed genocide, crimes against humanity and ethnic cleansing against the Rohingya. On July 24, 2025, OFAC determined that circumstances no longer warranted including several persons and companies —among them Aung Hlaing Oo and the MCM group— and removed them from the SDN list. Myanmar illustrates how a regime is sanctioned in layers and how OFAC selectively adjusts the list.
December 5, 2025 LB confirmed
Lebanon: Hezbollah's financial network and the blurred line between political actor and designated group
The case showing the hardest boundary in PEP analysis: the actor that is both a political party and a designated organization. Throughout 2025, OFAC maintained designations against Hezbollah's financial network —an entity that in Lebanon functions as a political party with parliamentary representation and, simultaneously, is designated a terrorist organization by the U.S. The designations reach financiers, shell companies and facilitators moving funds for the organization. For diligence, the case illustrates that the 'PEP' category and the 'sanctioned entity' category can overlap in a single actor when a political organization is designated: distinguishing the elected official from the designated financial operator requires relationship analysis, not just names.
June 30, 2025 PA confirmed
The Ibero-American PEP exposure map: eight countries where Diálogo Ciudadano's graph closes the regional blind spot
The event consolidating the product's moat: the Ibero-American coverage that Anglo providers cover worse. By mid-2025, the landscape of corruption and narcotics designations spans at least eight Ibero-American countries with documented PEP exposure: Mexico, Guatemala, El Salvador, Dominican Republic, Paraguay, Ecuador, Colombia and Panama. For each there are OFAC designations, convictions or proceedings that Diálogo Ciudadano's Mapa del Poder graph can link to their local corporate and family networks. This is the central sales argument: World-Check and Dow Jones have the names, but granular knowledge of Ibero-American relationships —who is related to whom, which company is controlled by whom— is where a specialized regional provider adds differential value. The eight-country map is the moat's frontier.
October 14, 2025 KH confirmed
Cambodia: Prince Group and Chen Zhi, 146 designations against a scam empire with a political-leadership nexus
The Asian case showing the convergence of transnational organized crime and political exposure. On October 14, 2025, the U.S. and the UK acted against the Prince Group, a Cambodia-based transnational criminal organization, with 146 designations. Its chairman, Chen Zhi, headed an empire of scam compounds operating with forced labor. Treasury cut Huione Group from the financial system via PATRIOT Act section 311. Press documents the nexus with Cambodia's political leadership, including the circle of prime minister Hun Manet. Billions in crypto were seized. For diligence, it illustrates how a corporate-facade organization can hide both forced labor and PEP connections at the highest level.
April 24, 2025 IR confirmed
Iran: senior security officials designated for human rights, the PEP angle distinct from the oil fleet
The case separating PEP risk from sectoral risk in the same country. While much of Iran's sanctions target the shadow fleet and oil exports (sectoral risk), on April 24, 2025 OFAC designated four senior officials of Iran's security apparatus for human-rights abuses, under Executive Orders 13553 and 13846. This angle —the official as a PEP for their role in repression— is methodologically distinct from tracking vessels or cargoes. For diligence, a single country generates two kinds of exposure: that of the politically exposed individual (which this tracker follows) and that of the sanctioned asset or sector (which 'shadow-fleet-sanctions' follows). Separating them is part of competent screening.
October 17, 2025 HT confirmed
Haiti: the UN sanctions regime against gang leaders, where the state vacuum makes the criminal the de facto power
The case inverting PEP logic: not a politician turning criminal, but a criminal filling the state vacuum. In October 2022, via resolution 2653, the UN Security Council imposed for the first time in over five years a new sanctions regime —travel ban, asset freeze and targeted arms embargo— against individuals and entities responsible for actions threatening peace in Haiti, targeting criminal gang affiliates. The regime has been maintained: resolution 2752 (2024) renewed it and, in 2025, the Committee added two entities on July 8 and the Council added two individuals on October 17 via resolution 2794, leaving nine individuals and two entities on the Committee's list. The United States called for additional designations. In Haiti, amid the collapse of state authority, gang leaders function as the de facto power, blurring the line between the criminal actor and the politically exposed figure in reverse. PEP risk does not always originate in office: sometimes real power resides in whoever controls territory.
June 26, 2024 HN confirmed
Honduras: ex-president Hernández sentenced to 45 years, a narco-state network and the later pardon reopening the cycle
The case combining criminal conviction, a complete network and political reversibility. On June 26, 2024, a New York federal court sentenced former Honduran president Juan Orlando Hernández ('JOH') to 45 years for drug and weapons trafficking, after it was proven he received narco bribes and facilitated the transit of some 400 tons of cocaine. The network is complete: his brother Tony Hernández was sentenced to life; former police chief Juan Carlos 'El Tigre' Bonilla and ties to former president Porfirio Lobo Sosa complete the narco-state graph. The cycle notably reopened: in November 2025, Hernández received a pardon from Donald Trump. The case brings together the three elements —final conviction, family-and-power network, and reversibility— that make PEP monitoring a continuous task.
August 8, 2025 GT confirmed
Guatemala: the chain of sanctioned officials mapping a state-capture network
The case showing how several individual designations, read as a graph, reveal a network. OFAC has sanctioned under E.O. 13818 a succession of Guatemalan officials: Gustavo Adolfo Alejos Cámbara (former private secretary to Álvaro Colom), Felipe Alejos Lorenzana (member of Congress) and Luis Miguel Martínez Morales for government-contract bribery. Press documents the regional pattern: the Magnitsky Act has reached Latin American officials from several countries —Dominicans, a Cuban, four Nicaraguans of the Ortega regime, three senior Bukele officials. The graph connects designations a flat list presents as isolated.
March 21, 2025 US confirmed
Tornado Cash: the delisting after the 5th Circuit ruling marks the legal limit of who can be sanctioned
The case defining a legal boundary of the sanctions power, relevant to on-chain risk. On March 21, 2025, OFAC delisted Tornado Cash, a cryptocurrency mixer, after a 5th Circuit Court of Appeals ruling that immutable open-source smart contracts do not constitute 'property' that can be blocked under IEEPA. The decision establishes that OFAC's power is not unlimited: there are technologies —autonomous ownerless software— that escape the category of sanctionable property. It is the crypto counterpart of the judicial limits that also affected the Illumina/GRAIL case in competition. For on-chain diligence, the case establishes that a protocol is not the same as a person or entity: screening must distinguish between addresses controlled by actors and autonomous code.
March 6, 2026 EU confirmed
The RCA blind spot: why flat-list PEP screening fails and the relationship graph sells
The market datum justifying the tracker as a product. In the 2026 PEP and sanctions screening guide, the industry describes the blind spot almost every program leaves open: Tier 4, relatives and close associates (RCAs). If a finance minister is corrupt, they rarely put the money in their own name; they put it in their spouse's or children's. The 2026 challenge is not 'checking a list' but managing volume: global lists change daily. Platforms like OpenSanctions integrate data from 360 global sources and license commercial users: demand for relationship data, not just names, is structural.
March 18, 2026 US confirmed
The OFAC landscape 2025-2026: 1,300+ designations, Syria lifted, Venezuela in transition after Maduro's apprehension
The synthesis giving the tracker systemic context and capturing its dynamic nature. In the first year of the second Trump administration, OFAC imposed sanctions on over 1,300 individuals and entities, prioritizing cartels and counternarcotics, Southeast Asian scam networks, Iran's shadow fleet and banking, and China. The period combines tightening and relief: comprehensive sanctions on Syria were lifted after the regime change; Venezuela entered a transition after Nicolás Maduro's apprehension in January 2026; and the October 2025 relief on Rosneft and Lukoil was modulated in March 2026. The lesson for the graph: a PEP's or entity's exposure status is not static —it changes with geopolitics— so the datum must carry a date and source, and monitoring must be continuous.
January 28, 2026 EU confirmed
List divergence: 28 UK regimes, the EU's autonomous regimes and OFAC — the cross-source challenge the graph solves
The event sizing the fragmentation of sanctions lists and why a unified graph adds value. The 2026 landscape shows parallel architectures: the UK maintains 28 autonomous and mixed sanctions regimes —adding, for example, 13 new designations under the Global Anti-Corruption Regime; the European Union operates its own Global Human Rights Regime (adopted December 2020) and regimes it designates independently of the U.S.; and OFAC administers over 30 programs. The compliance consequence is direct: a politically exposed person or entity may appear on one jurisdiction's list and not the others, and ownership rules differ (the EU and U.S. use the 50% threshold; the UK is evaluating moving to '50% or more'). The industry's declared challenge is not checking a list, but managing the volume and divergence of many. The value is not in replicating a list —that already exists— but in cross-referencing all sources in a unified relationship graph showing, for each Ibero-American node, in which jurisdictions it is exposed. Exactly what the Mapa del Poder enables building.
August 7, 2025 US confirmed
The Magnitsky corpus: 262 persons, 330 entities and 157 vessels under E.O. 13818
The datum quantitatively proving why the graph matters more than the list. Per Congressional Research Service (CRS) analysis, the corpus of designations under Executive Order 13818 (Global Magnitsky) includes 262 persons, 330 entities and 157 vessels. The ratio is the key: there are more designated entities than persons. This means that, on average, each sanctioned person drags more than one entity —companies, shells, vehicles— onto the list. A screening that only searches person names misses most of the corpus, which is linked entities. The PEP→company graph is not an analytical luxury: it is the only way to capture the real structure of exposure, where the person→entity ratio exceeds one.
September 8, 2025 EC confirmed
Ecuador: Los Lobos and Los Choneros designated terrorists, the Andean nexus with Mexican cartels reshaping regional risk
The case showing the spread of sanctions risk into the Andes and its entanglement with local political power. OFAC sanctioned the Ecuadorian organization Los Lobos and its leader Wilmer Geovanny Chavarría Barre ('Pipo'), after the prior designation (February 7) of Los Choneros; the State Department designated both as Foreign Terrorist Organizations (FTOs) and Global Terrorists (SDGTs). With thousands of members, Los Lobos emerged as Ecuador's largest drug-trafficking organization and, per the State Department, attacks public officials, judges, prosecutors and journalists. These groups are linked to the Mexican Sinaloa and CJNG cartels —Los Lobos provides security services to CJNG in Guayaquil— and to illegal gold mining. In January 2024 president Daniel Noboa declared an 'internal armed conflict' and designated 22 gangs as terrorist. Sanctions risk is no longer concentrated in the most obvious countries but distributed across the Andean region. The tracker records the designations; assessments are attributed to their sources.
October 31, 2025 CO reported
Colombia: president Petro added to the SDN list, an extreme and disputed sitting-head-of-state PEP case
The boundary case of PEP risk: a sitting head of state on the sanctions list. On October 31, 2025, OFAC added Colombian president Gustavo Petro to the SDN list, in an action without recent precedent against a sitting Latin American leader. The measure —whose basis and legitimacy have been subject to opposing readings— comes amid a period of strong bilateral tension. It is part of a broader shift: in February 2025 the U.S. designated eight Latin American cartels as terrorist organizations. The tracker records the verifiable fact —SDN inclusion— and attributes assessments of its motive to sources, adopting none; confidence is marked 'reported' given the disputed and developing nature of the case. It is the most extreme example of why PEP screening cannot ignore sitting heads of state.
August 12, 2025 CD confirmed
DR Congo: sanctions on armed groups and illegal critical-mineral mining
The case connecting corruption, conflict and the critical-minerals supply chain. On August 12, 2025, OFAC sanctioned entities linked to armed-group violence and critical-mineral sales in DR Congo, under E.O. 13413. Eastern DRC has suffered thousands of civilian deaths, exacerbated by the M23 group's control (Rwanda-backed, designated by the U.S. and the UN). The sanctions targeted groups like PARECO-FF, which controlled mining sites in Rubaya —rich in critical minerals used in electronics—, generating revenue via illegal fees, smuggling, forced labor and executions. A 'clean' mineral at the border may originate in a mine controlled by a sanctioned group.
August 8, 2025 BR confirmed
The Brazilian STF justice case: when a Magnitsky sanction becomes politically disputed
The case forcing the tracker's methodological caution. In 2025, the Trump administration applied the Global Magnitsky Act against a justice of Brazil's Federal Supreme Court (STF), per coverage, over alleged abuses in the criminal proceeding of former president Jair Bolsonaro. Unlike designations for documented corruption (Cartes, the Guatemalans), this case illustrates the instrument can be used in contexts of political dispute: the press notes its application was questioned and generated opposing readings about a possible 'double standard'. An SDN designation is a verifiable fact, but the motive and its legitimacy may be disputed. The tracker records the fact —list inclusion— and attributes assessments to their sources, adopting none.
January 17, 2025 BA confirmed
Bosnia: Milorad Dodik's patronage network, the layered PEP graph of a secessionist leader
The European case illustrating a patronage network modelable in layers. On January 17, 2025, the U.S. expanded sanctions on the network of Milorad Dodik, president of Republika Srpska (the Bosnian Serb entity), under Executive Order 14140, which addresses corruption and threats to the stability of Bosnia and Herzegovina. The action built on prior 2023-2024 designations, mapping a patronage structure: the political leader, his associates and the entities sustaining his power. For diligence, Dodik is a textbook example of how a PEP weaves a control network understood only in layers —the individual, his circle, his vehicles—, exactly what a relationship graph captures and a flat list fragments.
December 9, 2025 US confirmed
The oligarch's fiduciary: an OFAC settlement revealing how PEP exposure hides in family trusts
The enforcement case illustrating the subtlest exposure-transmission mechanism: the trust. In December 2025, OFAC reached a $1,092,000 settlement with an individual ('U.S. Person-1') over 122 apparent Russia-related sanctions violations. The mechanism is the lesson: between April 2018 and June 2022, this person acted as fiduciary of a U.S.-based family trust of a sanctioned Russian oligarch, dealing in blocked property and providing prohibited services. The oligarch's exposure was not in their name or in an obvious shell company, but hidden in the structure of a family trust administered by a U.S. third party. OFAC classified the conduct as non-egregious, not voluntarily disclosed, and noted the substantial cooperation. A parallel case: a prior settlement with International Petroleum Investment tied to investments of oligarch Suleiman Kerimov maintained for four years after his 2018 designation. For diligence, the trust is the vehicle where true ownership disappears, and only relationship analysis detects it.
December 16, 2025 US confirmed
Fintech and crypto in the crosshairs: Exodus, ShapeShift, Payoneer and the extension of the screening duty across the payment chain
The case showing how the PEP/sanctions detection duty extends to actors that are not traditional banks. Throughout 2025-2026, OFAC expanded its enforcement to fintech and crypto platforms, making clear that digital assets are not a 'sanctions-free zone.' On December 16, 2025 it reached a $3.1 million settlement with Exodus, a non-custodial software wallet provider: although Exodus did not process transactions directly, it acted as a front end for third-party services charging a fee, and per OFAC it continued providing assistance enabling users in Iran to circumvent controls —12 egregious instances included repeated customer-support recommendations to use VPNs to bypass geo-blocking. In September 2025 it penalized the crypto exchange ShapeShift; other cases include Poloniex ($7.6M), Kraken ($362K), BitPay ($507K) and Payoneer ($1.5M, over 2,260 violations). Sanctions obligations apply to support practices, user experience and technical configurations, not just direct processing. This broadens the universe of PEP-graph buyers: any platform onboarding or processing payments needs screening. 'Sanctions risk exists wherever KYC exists.'
February 28, 2025 US confirmed
Crypto identifiers on the SDN list: 1,245 designated wallets and on-chain screening as a new graph layer
The component adding the on-chain dimension to the PEP graph. In early 2025, the number of cryptocurrency addresses on OFAC's SDN list reached about 1,245 wallets, an increase of around 32%. Bitcoin represents the majority (63-65%) of designated addresses. Iran's Revolutionary Guard Corps (IRGC) appears with associated crypto addresses, and OFAC executed its first sanction against a DeFi protocol (for about $150 million). For diligence, the datum consolidates a new graph layer: a sanctioned PEP's or entity's exposure is no longer tracked only by names and companies, but also by on-chain wallets. Complete screening must cross blockchain addresses in real time, because the sanctioned actor's money can move across the chain.
December 31, 2025 US confirmed
$265 million in penalties and the GVA Capital case: the real cost of failing PEP screening, and why the product sells
The event quantifying the tracker's commercial thesis: failing to detect exposure is extremely costly. In 2025, OFAC's total fines and settlements exceeded $265 million —a dramatic increase from about $49 million in 2024—, driven by expanded regulatory focus on digital assets, fintech and venture capital. OFAC took 14 public enforcement actions, focusing on Russian-sanctions violations by non-bank 'gatekeepers': private equity funds, real estate companies and attorneys. The flagship case: GVA Capital received the statutory maximum penalty of about $215.99 million, explicitly because the company made no voluntary disclosure and the conduct was deemed egregious —related to maintaining investments of a sanctioned Russian oligarch. OFAC expects companies to 'look beyond legal formalities to the underlying practical and economic realities' of their relationships, and even rejected legal opinions concluding that immediate clients were not owned by a sanctioned party. OFAC operates under strict liability. The cost of not detecting a hidden relationship is measured in hundreds of millions, and flat-list screening is not enough because it does not see relationships.
April 30, 2026 KH confirmed
Senator Kok An and the Poipet casinos: when the sitting PEP is designated for running scam centers
The case closing the circle between political office and organized crime in Cambodia. On April 30, 2026, OFAC designated Cambodian senator Kok An along with 28 linked entities, including Crown Resorts and Anco Brothers, for their role in the Poipet and Sihanoukville scam centers. Kok An, a sitting Senate member, controlled casino complexes used as a facade for fraud operations. Per IC3 data, scams linked to these networks reportedly generated losses on the order of $7.2 billion. Unlike the Prince Group case (a businessman with a political nexus), here the designee is directly a sitting legislator: the PEP is not behind the network, they are the network.
