New Report Spotlights Agile Tool to Counter Corrupt and Criminal Networks

US Treasury’s Blocked Pending Investigation sanctions listings can deliver speed and agility to match fast-evolving illicit operations

The tool’s reemergence offers opportunities for NGOs, civil society, and financial institutions to provide critical information to support rapid action by sanctions authorities

 

June 17, 2025 (Washington, DC) – A new report by The Sentry, “Targeting Dynamic Illicit Financing Networks with Blocked Pending Investigation (BPI) Listings,” puts a spotlight on BPI sanctions designations as a tool to counter corrupt and criminal networks.

Michelle Kendler-Kretsch, Deputy Director of Investigations at The Sentry, said: “Corrupt and kleptocratic networks can be complex, fast moving, and well resourced—conditions that can blunt the impact of sanctions. In these whack-a-mole like conditions, tools like blocked pending investigation listings offer the speed and flexibility needed to keep pace. Crucially, success in the deployment of BPIs hinges on timely information sharing, strategic deployment, and strong compliance. When NGOs contribute in-depth information and knowledge and financial institutions uphold rigorous due diligence, BPI listings can become a powerful lever to disrupt illicit networks and reinforce the effectiveness of sanctions.”

BPI listings establish the same restrictions—such as asset freezes—on a listed entity as do standard sanctions listings, enabling immediate and hard-hitting financial pressure on these entities and their networks.

As The Sentry’s report details, the use of public BPI designations could strengthen the ability to target conflict financing, sanctions evasion, and kleptocratic networks.

Public BPI listings also signal the priorities of the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) to NGOs and civil society groups, highlighting where sharing or publishing related information would be effective in supporting OFAC.

Laura Ferris, Director of Illicit Finance Policy at The Sentry, said: “Financial institutions and NGOs can play critical roles in maximizing BPI listings. Financial institutions can help to swiftly disrupt fast-moving corrupt and kleptocratic networks by fully implementing BPI listings into compliance responses, if they have not done so already. NGOs can help by using intelligence gathered from fieldwork and investigations to fill critical information gaps for financial institution compliance professionals and the government. By understanding the authority, financial institutions and NGOs can be at the ready to effectively respond.”

Recent BPI listings by OFAC have targeted dangerous, fast-evolving networks operating in dynamic environments:

• In September 2023, OFAC listed as BPI four companies that were part of a corporate network supporting the operations of Russia’s mercenary Wagner Group, an entity exposed in investigations by The Sentry for the looting of gold and diamonds and campaigns of mass murder, rape, and torture of civilians.
• On June 6, 2024, OFAC again invoked BPI listings, adding seven companies in the United Arab Emirates (UAE) to the US Specially Designated Nationals (SDN) list, citing “potential involvement in activities violating US sanctions on Sudan.”

The Sentry’s report highlights how financial institutions and NGOs can enhance OFAC’s use of BPI listings.

Read the full report: https://thesentry.org/reports/bpi-listings/

For media inquiries please contact: Greg Hittelman, Director of Communications, gh@thesentry.org

 

About The Sentry
(Short descriptor for press use: “The Sentry, an investigative organization that tracks corruption.”)
The Sentry is an investigative and policy organization that seeks to disable multinational predatory networks that benefit from violent conflict, repression, and kleptocracy. Pull back the curtain on wars, mass atrocities, and other human rights abuses, and you’ll find grand corruption and unchecked greed. These tragedies persist because the perpetrators rarely face meaningful consequences. The Sentry aims to alter the warped incentive structures that continually undermine peace and good governance. Our investigations follow the money as it is laundered from war zones to financial centers around the world. We provide evidence and strategies for governments, banks, and law enforcement to hold the perpetrators and enablers of violence and corruption to account. These efforts provide new leverage for human rights, peace, and anti-corruption efforts. Learn more at: https://TheSentry.org