Hidden in Plain Sight

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Across
  1. 2. Freezing assets belonging to sanctioned persons or entities
  2. 5. Party that sits between others in a transaction chain
  3. 6. Interconnected parties that can enable sanctions evasion
  4. 7. A complete ban on trade with a country or region
  5. 9. U.S. Treasury office responsible for administering economic sanctions
  6. 10. Sending goods or technology to another country
  7. 11. Process of verifying counterparties and ownership structures
  8. 14. The act of formally placing a party under sanctions
  9. 16. Company with little real activity often used to obscure ownership
  10. 17. The other party involved in a transaction
  11. 18. Attempt to circumvent sanctions restrictions
  12. 19. Financial transfers that can trigger sanctions compliance checks
Down
  1. 1. Legal authority that determines which sanctions rules apply
  2. 3. Checking parties against sanctions lists before doing business
  3. 4. Government action that blocks access to assets
  4. 8. Moving transactions through different financial channels
  5. 9. A key factor in determining whether a company is indirectly sanctioned
  6. 12. Official register of sanctioned individuals or entities
  7. 13. List of individuals and entities blocked under U.S. sanctions programs
  8. 15. Government restrictions on trade or financial activity with specific countries or entities