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
Partner
Morgan Lewis

Brent Carlson
Founder
Red Flag Rising

Kimberly Smith
Founder + CEO
SILO Compliance
Download Slides
Get all the webinar slides and handouts, packed with valuable insights and practical tips.
