If you are getting a little confused about the number of sanctions the US has put on various people for violations of sanctions put on specific countries for their actions, join the club. Russians are sanctioned; Chinese companies are sanctioned; Iranian government officials, North Koreans, et al are sanctioned too. It is very confusing even to keep up on the number of sanctions that are the basis for these kinds of actions. The latest one is jet fuel to Syria, which I actually did not know was on anyone's sanctions list.
Anyway, the US has sanctioned 5 Russians and 3 Syrians for moving jet fuel to Syria. The Russians worked for a freight forwarder who was identified as a violator, and set up a shell company to continue their activities. They must have thought, like ZTE and an unnamed co-conspirator, that setting up shell companies was the best way to avoid being discovered on violations. It didn't work for ZTE and it didn't work for those Russians either, but it does seem to be a very popular way to try to avoid detection. Those of you who remember the Panama Papers remember how many of these shell operations were set up all over the world, and this was only one law firm, in one country that ranked 4th in the creation of shell companies. That means there are a boat load of these things out there. Anyway, you can read all about this particular case in the Wall Street Journal, if you are so inclined. Those who don't own a shell company should probably check it out. Everybody else you know has one.
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