While a number of companies and individuals may be in violation of sanctions unknowingly – often because they are unaware of the connections and business dealings of their commercial partners – a separate group of actors is well informed and knowingly involved in the business of sanctions busting. In effect some of the major target countries on the OFAC list, including Russia and Iran or, in Latin America, Cuba, Venezuela, and Nicaragua, have supported a semi-clandestine network of intermediaries, traders, freight shipment companies, accountants, and others who are used to evade sanction regulations on a daily basis.
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