VERITAS · CASE FILE · SANCTIONS-MAZEOFFENDER'S PLAYBOOK · 60–90 min · 1–6 playersAN INVESTIGATOR'S GAMESANCTIONSMAZEEvade the regime. Then dismantle the maze.№098
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OFFENDER'S PLAYBOOK · 60–90 min · 1–6 players

Sanctions Maze

Evade the regime. Then dismantle the maze.

Route a sanctioned payment through nested ownership, front companies and trade invoicing. Then flip the board and dismantle the same maze as an OFAC analyst.

⚑ Educational simulation. Every evasion move is followed by the analyst counter-move.
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Learning objectives

  • 01Understand ownership-threshold evasion (50 % rule)
  • 02Map front-company and trade-invoicing techniques
  • 03Reverse-engineer a sanctions-evasion structure

Standards mapping

FATF Recommendations and CPD credit

Learning objectiveFATF
Understand ownership-threshold evasion (50 % rule)R.6, R.7, R.24
Map front-company and trade-invoicing techniquesR.16
Reverse-engineer a sanctions-evasion structureR.6, R.7, R.24
  • R.6 Targeted financial sanctions related to terrorism and terrorist financing. Ownership-threshold evasion is scored against designation logic.
  • R.7 Targeted financial sanctions related to proliferation financing. The maze mirrors proliferation-network structuring.
  • R.16 Wire transfers. Payment routing fires correspondent screens.
  • R.24 Transparency and beneficial ownership of legal persons. Naming the ultimate controller is the analyst win condition.

Also covers: OFAC 50 Percent Rule guidance · EU restrictive-measures ownership and control guidance · UNSC resolutions on proliferation financing

CPD credit rationale

1.5 structured hours (1.5 verifiable) — streams: Sanctions compliance, AML/CFT compliance, Financial investigation.

Hours are claimed against structured learning: facilitated play against a published set of learning objectives, decisions scored on a rubric, and a written debrief retained by the participant. The analyst round is the assessed component: the controller must be named in three moves with reasoning recorded.

Evidence retained: Ownership maze diagram; Analyst round move log.

Table setup · 1–6 players

Best with 4 (two designers, two analysts)

1Solo study

Build the maze, route the payment, then flip to analyst mode.

2Head-to-head

Designer versus analyst; the analyst has three moves per maze.

3–4Case cell

S1–S3 build, S4 analyses; the maze is revealed only one node at a time.

5–6Full table

Add S5 and S6 so screening and designation timing become live decisions.

Seats at the table

  1. S1Structuring adviserChooses jurisdictions and stake sizes.
  2. S2Nominee shareholderHolds the layers that keep each stake below threshold.
  3. S3Trade counterpartyMoves the goods and the payment.
  4. S4OFAC / sanctions analystApplies the aggregate-control test.
  5. S5Correspondent bank screenerOwns payment screening and the soft alert.
  6. S6Licensing / policy officerDecides designation timing and what it burns.

Team rules

  • 01One seat, one voice: a decision is only locked when the seat that owns it says so out loud.
  • 02Every locked decision needs a one-sentence justification the seat would defend in a real file.
  • 03Any player may call a 60-second 'case conference' once per round to force a table discussion.
  • 04The facilitator (or the highest-scoring player of the previous round) keeps time and reads the outcome cards.
  • 05Aggregate-control disputes are settled by reading the rule aloud, not by majority vote.

Rotation — Swap benches after each maze; the second maze must not reuse a jurisdiction from the first.

How to play

  1. 1.Design a 5-node ownership maze that keeps every entity below the 50 % control threshold.
  2. 2.Route a $10m payment through the maze. Correspondent-bank screens fire on obvious triggers.
  3. 3.Analyst round: name the ultimate controller in 3 moves or fewer.

Design the maze

Set the jurisdiction and stake for each of 5 nested entities. Keep every stake at or below 49 % to try to defeat the US OFAC 50 % ownership rule.

Node ATop layer
49%
Node BSecond layer
49%
Node CThird layer
49%
Node DFront company
49%
Node ETrading entity
49%

Session extension · +75 minutes

Take the session to full length.

Three additional facilitated missions with their own debrief checkpoints. Run them straight after the online round to take this title to a 60–120 minute workshop. Every checkpoint is self-marking — tick what you can genuinely defend.

Two designated persons hold 30 % each through different chains.

Tasks

  1. 01Redraw the maze and test it against aggregation rules.
  2. 02Identify the node where the aggregate crosses the threshold.
  3. 03State how a screening system would or would not see it.

Checkpoint · Mark the aggregation test.

Debrief · discuss with your team

  • Q1.Which node was the weakest link?
  • Q2.What data would your agency need to run this de-anonymisation live?