Targeting Dynamic Illicit Financing Networks with Blocked Pending Investigation (BPI) Listings

By Michelle Kendler-Kretsch

The US Department of the Treasury’s Office of Foreign Assets Control (OFAC) appears to have a renewed interest in a sanctions tool first used in 2001: blocking individuals and entities pending investigation. Used in two recent sets of listings, the tool offers the agility and speed necessary to quickly and efficiently dismantle financing networks and sanctions evasion tactics. Its strategic application warrants closer attention from financial institutions, who must be responsive to their compliance obligations. Non-government organizations (NGOs) may be aware of opportunities where they can advocate for OFAC to take greater advantage of this option, particularly in cases related to sanctions evasion and conflict financing. In parallel, NGOs can also play a vital role by sharing information that supports implementation and, where applicable, reinforces the credibility of these provisional designations.

Washington, DC: The Sentry, 2025. 22p.