Authored by: Jing Yunfeng, Li Zhenghao, Dai Menghao, Hou Peng, Zhao Xinhua and Sun Xing
On March 31, 2026, the U.S. Department of the Treasury’s Office of Foreign Assets Control formally issued a significant sanctions guidance document—the Guidance on Sham Transactions and Sanctions Evasion. This document, for the first time, provides a systematic definition of sham transactions, explicitly identifies seven key risk indicators, and highlights the potential risks of trust-based legal structures being exploited to evade sanctions.