OFAC Follows the Money: Brokers and Importers Get Named Next
If FinCEN’s oil-smuggling typologies keep producing high-value SAR clusters—and investigators can tie specific shipments to identifiable companies—Treasury’s next move is to sanction the “respectable” layer: brokers, logistics firms, and U.S.-linked importers that make stolen crude look clean. The trigger is documentation: repeat counterparties, consistent routing, and payment narratives that match the typology (like mislabeling cargo).
