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sanctions-screening
How AI Is Actually Changing Sanctions Screening (and Where It Shouldn't)
FinCEN's 2026 NPRM signals that demonstrably effective AI adoption may count in enforcement decisions. Where AI genuinely improves sanctions screening — and the five boundaries where handing the decision to a model creates more regulatory risk than it removes.
The OFAC 50 Percent Rule: Sanctions Ownership and the 2026 Sham Transactions Guidance
A practitioner's guide to the OFAC 50 Percent Rule — ownership aggregation, indirect ownership, FAQ 401 examples, the March 2026 Sham Transactions Guidance, the GVA Capital, IPI Partners, and Gracetown enforcement actions, and the BIS Affiliates Rule taking effect November 10, 2026.