Sanctions Evasion via Informal Channels Exposes Persistent AML Risks

A recent Department of Justice (DOJ) case underscores the continued vulnerability of the financial system to relatively low-value but high-risk sanctions evasion schemes. On 24 March 2026, Uruguayan national Irazmar Carbajal De Jesus pleaded guilty to conspiring to operate an unlicensed money transmitting business to move funds linked to a sanctioned Venezuelan official into the United States. 

The facts are straightforward but instructive. Carbajal agreed to transfer approximately $99,500 in cash from the Dominican Republic into a US bank account, despite being informed that the funds originated from a sanctioned individual connected to the Venezuelan government. The scheme relied on classic financial crime techniques, including falsified invoices, the use of multiple accounts to obscure the transaction trail, and coded language to disguise the nature of the funds. 

From a compliance perspective, the case illustrates how sanctions evasion frequently intersects with unlicensed money services businesses (MSBs). By operating outside regulated financial channels, such actors bypass core safeguards including customer due diligence (CDD), transaction monitoring, and suspicious activity reporting. This creates systemic exposure not only for those directly involved but also for financial institutions that may unknowingly process such transactions.

Notably, the relatively modest value of the transaction is significant. Enforcement action in this case demonstrates that US authorities continue to prioritise sanctions compliance irrespective of transaction size. The presence of aggravating factors, such as deliberate concealment and knowledge of a sanctioned nexus, is sufficient to trigger criminal liability. 

The use of intermediaries and third-party facilitators remains a critical risk vector. Organisations engaging external agents, particularly in higher-risk jurisdictions or corridors, must ensure robust due diligence and ongoing oversight. The fabrication of invoices in this case also highlights persistent weaknesses in trade-based money laundering controls, where documentation is used to create a veneer of legitimacy.

Carbajal now faces a maximum sentence of five years’ imprisonment, with sentencing scheduled for 12 June 2026.   The case reinforces a consistent DOJ enforcement message: sanctions are a national security tool, and attempts to circumvent them through informal financial networks will be investigated and prosecuted.

For firms, the takeaway is clear. Effective sanctions compliance requires not only screening but also scrutiny of transaction purpose, counterparties, and payment structures, particularly where behavioural red flags such as coded communications or unusual routing patterns emerge.

Read the press release here.