SECONDARY SANCTIONS: CHAINS OF LIABILITY, INTERMEDIARIES, AND EXTRATERRITORIAL PRESSURE
This report examines secondary sanctions as a mechanism of extraterritorial coercion that transfers legal and compliance risks from the primary target to intermediaries and financial institutions. The document explores key pressure scenarios from the U.S. Treasury and OFAC, the protective frameworks of the EU Blocking Statute, and sanctions-evasion typologies identified by FATF in 2025. It places a particular emphasis on anticipatory market behavior and legal strategies for managing jurisdictional conflicts.
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