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Sanctions Evasion Risk: Emerging Issues, Trends and Typologies cover

Sanctions Evasion Risk: Emerging Issues, Trends and Typologies

September 2026

Sanctions compliance is becoming more complex than identifying a name on a screening list.

In this AML Grey Matters webinar, Michael Huneke and Brent Carlson examine emerging sanctions-evasion risks, recent enforcement developments and when firms may need to look beyond formal ownership thresholds and counterparty certifications.

The discussion covers:

  • Emerging sanctions-evasion methods and typologies
  • Trusts, layered ownership structures and OFAC’s 50% Rule
  • What “knowledge” and “reason to know” can mean in practice
  • US, EU and UK approaches to sanctions circumvention
  • Cayman’s new Compliance Rule 8.2(f)
  • Identifying and documenting higher-probability risks

Watch the recording to explore recent cases, practical warning signs and how compliance teams can take a more risk-based approach to sanctions due diligence.

Presenters

Michael Huneke

Michael Huneke

Partner

Morgan Lewis

Brent Carlson

Brent Carlson

Founder

Red Flag Rising

Kimberly Smith

Kimberly Smith

Founder + CEO

SILO Compliance

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