Sanctions Evasion Network MCP Server

Structural sanctions evasion detection through ownership chain tracing, director network mapping, and multi-database hit correlation across 8 corporate and sanctions databases. This MCP server goes beyond simple name matching to trace corporate structures across 6+ jurisdictions, detect nominee director patterns, score jurisdictional risk using FATF cascade weighting, and produce Evasion Probability Scores (0-100) that quantify the likelihood a corporate structure is designed to evade sanctions.

What data can you access?

Data Point	Source
US Treasury SDN and blocked persons lists	OFAC Sanctions
Consolidated global sanctions and PEP data	OpenSanctions
International wanted persons and notices	Interpol Red Notices
Corporate registrations across 140+ jurisdictions	OpenCorporates
UK company registrations, officers, and PSC data	UK Companies House
Legal Entity Identifiers and ownership chains	GLEIF LEI
Canadian federal corporate registry	Canada Corporations
Australian business number registry	Australia ABN

MCP Tools

Tool	Price	Description
deep_entity_screening	$3.00	Deep screening across all 8 sources with composite Evasion Probability Score
ownership_chain_trace	$3.00	Trace ownership chains across 5 corporate registries with shell company indicators
director_network_map	$3.00	Map director networks for cross-directorship, nominee patterns, and address clustering
jurisdictional_risk_score	$3.00	Score jurisdictional risk using FATF blacklist/greylist and secrecy indicators
fuzzy_sanctions_match	$3.00	Fuzzy multi-database sanctions matching with transliteration support
beneficial_owner_identification	$3.00	Identify beneficial owners through corporate structure traversal + sanctions screening
trade_route_risk_assessment	$5.00	Assess trade route risk for sanctions circumvention with composite scoring

Data Sources

• OFAC Sanctions -- US Treasury Specially Designated Nationals (SDN) list and blocked persons with entity details, aliases, and identification documents
• OpenSanctions -- Consolidated global sanctions database aggregating lists from EU, UN, US, UK, and other jurisdictions with cross-referencing
• Interpol Red Notices -- International wanted persons database for law enforcement-related screening
• OpenCorporates -- Global corporate registry data spanning 140+ jurisdictions with officers, filings, and entity status
• UK Companies House -- UK company registrations including Persons with Significant Control (PSC) data for beneficial ownership
• GLEIF LEI -- Legal Entity Identifier system with parent-child ownership relationships and fund relationships
• Canada Corporations -- Canadian federal corporate registry with director and officer information
• Australia ABN -- Australian Business Number registry for entity verification in the APAC region

How the scoring works

The MCP produces five scoring dimensions that combine into an Evasion Probability Score (0-100):

Ownership Chain Depth Score analyzes corporate nesting depth combined with jurisdictional risk at each ownership layer. Deep chains through secrecy jurisdictions receive higher scores. Shell company indicators (minimal economic substance, rapid incorporation, registered agent addresses) amplify the score.

Director Network Analysis maps cross-directorship patterns to detect nominee directors -- individuals serving as directors of many unrelated companies. Address clustering (multiple companies sharing registered agent addresses) and rapid incorporation patterns are additional indicators.

Jurisdictional Risk Cascade applies FATF grey/blacklist status, financial secrecy indicators, and corporate opacity scores to each jurisdiction in the ownership chain. Risk cascades through the chain, with each layer multiplying the jurisdictional risk.

Multi-Database Hit Correlation performs fuzzy matching with transliteration support across OFAC, OpenSanctions, and Interpol simultaneously. Hits across multiple databases with name variations receive the highest correlation scores.

Evasion Probability Score (0-100) is the composite probability that a corporate structure was designed to evade sanctions, combining all four dimensions.

Score Range	Verdict	Interpretation
0-20	CLEAR	No sanctions hits, simple corporate structure
21-40	LOW_RISK	Minor flags, standard corporate complexity
41-60	ELEVATED	Significant complexity or partial sanctions matches
61-80	HIGH_RISK	Multiple evasion indicators, enhanced due diligence required
81-100	CRITICAL	Strong evasion probability, recommend blocking

How to connect this MCP server

Claude Desktop

Add to your claude_desktop_config.json:

{
  "mcpServers": {
    "sanctions-evasion-network": {
      "url": "https://sanctions-evasion-network-mcp.apify.actor/mcp"
    }
  }
}

Programmatic (HTTP)

curl -X POST https://sanctions-evasion-network-mcp.apify.actor/mcp \
  -H "Content-Type: application/json" \
  -H "Authorization: Bearer YOUR_APIFY_TOKEN" \
  -d '{"jsonrpc":"2.0","method":"tools/call","params":{"name":"deep_entity_screening","arguments":{"entity":"Petrocom Holdings Ltd"}},"id":1}'

This MCP also works with Cursor, Windsurf, Cline, and any other MCP-compatible client.

Use cases for sanctions evasion intelligence

Enhanced Due Diligence for Complex Structures

Screen corporate structures with multiple layers and cross-border ownership for sanctions evasion indicators. Goes beyond name matching to analyze structural characteristics that facilitate sanctions circumvention.

OFAC Compliance Beyond Name Screening

Supplement standard OFAC SDN name screening with ownership chain analysis and director network mapping. Detect entities that use corporate layering to distance themselves from sanctioned persons.

Trade Finance Counterparty Verification

Screen trade finance counterparties for sanctions exposure through corporate structure analysis. Identify beneficial owners and jurisdictional risk factors before approving transactions.

Beneficial Ownership Investigation

Trace beneficial ownership through corporate structure traversal across 6+ jurisdictions. Screen discovered individuals against OFAC, OpenSanctions, and Interpol databases.

Follow-the-Money Corporate Analysis

Map corporate networks to trace financial flows and ownership connections. Identify nominee director patterns and shared registered agent addresses that indicate coordinated structures.

Trade Route Sanctions Risk Assessment

Assess complete trade route risk by combining sanctions screening with corporate structure analysis and jurisdictional risk scoring for counterparties along the route.

How much does it cost?

This MCP uses pay-per-event pricing. You are only charged when a tool is called.

The Apify Free plan includes $5 of monthly platform credits.

Example Use	Approximate Cost
Fuzzy sanctions match across 3 databases	$3.00
Ownership chain trace across 5 registries	$3.00
Trade route risk assessment (full composite)	$5.00
Screen 5 counterparties with deep screening	~$15.00

How it works

1. You provide an entity name (person or company) via any MCP client
2. The MCP runs up to 8 Apify actors in parallel querying OFAC, OpenSanctions, Interpol, and corporate registries across 5 jurisdictions
3. Scoring algorithms analyze the combined data -- ownership chains are traced, director networks are mapped, jurisdictional risk is cascaded, and sanctions hits are correlated
4. Structured JSON is returned with the Evasion Probability Score, verdict, per-dimension scores, signals, and recommendations

For the deep_entity_screening tool, all 8 actors run simultaneously: OFAC, OpenSanctions, Interpol, OpenCorporates, UK Companies House, GLEIF LEI, Canada Corporations, and Australia ABN. Results are combined into a comprehensive evasion report.

FAQ

Q: How is this different from standard sanctions screening? A: Standard screening does name matching against sanctions lists. This MCP traces ownership chains across 6+ corporate registries, detects nominee director patterns, and scores the probability that a corporate structure was designed to evade sanctions.

Q: Does this replace my sanctions screening vendor? A: No. This provides structural evasion detection that complements standard name matching. Use both for comprehensive sanctions compliance.

Q: How does fuzzy matching work? A: The system searches across OFAC, OpenSanctions, and Interpol with fuzzy name matching that accounts for transliteration variations, name ordering differences, and common aliases.

Q: Can it trace ownership through private companies? A: It traces ownership through publicly registered corporate entities. Private ownership information beyond what is filed with corporate registries (such as UK PSC data) is not available.

Q: Is it legal to use this? A: All data sources are publicly available government and international databases. See Apify's guide on web scraping legality.

Q: Can I combine this with other MCPs? A: Yes. Use alongside the Financial Crime Screening MCP for AML/CFT or the Export Control Screening MCP for dual-use technology compliance.

Related MCP servers

MCP Server	Description
ryanclinton/financial-crime-screening-mcp	AML/CFT screening and financial crime detection
ryanclinton/counterparty-due-diligence-mcp	Corporate KYB and counterparty verification
ryanclinton/export-control-screening-mcp	Export control and dual-use screening

Integrations

This MCP server is built on the Apify platform and supports:

• Apify API for programmatic sanctions screening pipeline integration
• Scheduled runs via Apify Scheduler for recurring counterparty monitoring
• Webhooks for triggering alerts when evasion probability scores exceed thresholds
• Integration with 200+ Apify actors for extending jurisdictional coverage