The mechanism. When OFAC adds names to the Specially Designated Nationals list — and it does this constantly, with fresh actions published in the Federal Register almost weekly — every dollar-clearing bank in the world runs the new names against every correspondent relationship it holds. Banks in Turkey, the UAE, Central Asia, and West Africa that suddenly look "high-risk by association" don't get cut off from the dollar system entirely; they get funneled toward the handful of U.S. institutions with the compliance infrastructure, licenses, and risk appetite to keep clearing them under enhanced due diligence. That funnel is correspondent banking, and it's a fee business: wire fees, FX spreads, trade-finance letters of credit, and advisory mandates to help foreign banks and corporates restructure around the new designations. Sanctions headlines get read as pure downside — fines, exited relationships, reputational risk. What they actually do is concentrate a shrinking pool of eligible dollar-clearing volume into fewer hands.
Who cashes in.