Company X exports goods to the US. One of Company X’s three directors is also the 100% shareholder and has recently been designated as a sanctions target by OFAC. The night before designation, the shareholder resigned from the director role and transferred 25% of his shares to his spouse, as well as 26% to a company that is managed by a trust in which he is one of the beneficiaries. Which tactics are being used to evade the sanctions restrictions that apply to the shareholder?