Sanctions Due Diligence for Business
Compliance services: Analysis of counterparties and transactions taking into account international sanctions restrictions.
About us
We have been providing legal support for international business for over 10 years. Our team brings together lawyers and analysts with practical experience working in leading financial and consulting companies, including departments that monitor compliance with EU, US, and UK sanctions legislation. We have practical experience in auditing complex corporate structures. We guarantee a confidential and individual approach to each project.
For the purposes of self-control and to comply with the requirements of banks and international carriers in the field of sanctions compliance, it is necessary to conduct an extended procedure for checking counterparties and transactions (COMPREHENSIVE DUE DILIGENCE), including:
Analysis of ownership structure and beneficiary chains, applying the 50% rule.
Verification of beneficiaries and persons making decisions on the transaction.
Assessment of secondary sanctions risks.
Search and analysis of information in the media, analysis of reputational risks.
Preparation of reports for internal compliance and banks.
Recommendations for minimizing sanctions risks in transactions.
Development of sanctions policy.
We offer the following services:
Quick check of a counterparty or transaction (Sanctions Check)
Description:
Checking a counterparty or goods for the risk of sanctions. We analyse: the presence of a company/person on sanctions lists (EU, US, UK, etc.), links to restricted jurisdictions, industry and goods restrictions.
Examples of risks:
- The company is formally ‘clean’, but its ultimate beneficiary or CEO is on the US or EU sanctions list.
- The organisation is registered in a ‘neutral’ country, but upon verification, it turns out that more than 80% of its turnover comes from transactions with sanctioned jurisdictions → there is a high risk of it being recognised as a ‘front company’.
- Financial restrictions by jurisdiction: the company is not included in the sanctions list, but its partner bank is under sanctions → payments in the international system will be blocked.
Result :
of the sanctions risk check: a written conclusion on the admissibility of the transaction, a list of identified risks
Contract review (light) for the presence of sanctions risks
Description:
Legal analysis of the contract text for compliance with sanctions legislation. Provisions that may lead to a violation of sanctions regimes are identified, the presence of necessary sanctions clauses is checked, and adjustments are proposed to minimise risks.
Examples of risky conditions:
- The contract provides for payments in a currency that always passes through banks in countries with strict sanctions filters.
- The text does not prohibit the re-export of products, which creates the risk of goods ending up in prohibited jurisdictions.
- The wording allows third parties to be involved without checking their sanctions status.
- The contract does not contain a clause stating that sanctions may be recognised as force majeure, which creates the risk of penalties if they are imposed.
Result :
of the contract analysis: conclusion with proposals for amending the text in accordance with the requirements of sanctions legislation.
Comprehensive analysis of foreign economic transactions
Description:
Comprehensive analysis and structuring of foreign economic transactions: verification of counterparties, analysis of contract terms, delivery routes and financial channels. Suitable for all companies that regularly engage in export and import operations.
Examples of risks:
- The products specified in the contract fall into the ‘restricted use’ category (e.g., chemicals, electronic components).
- The logistics chain includes transit through a jurisdiction under embargo.
- The transaction is financed through a bank that applies its own strict filters and refuses to process even formally ‘permitted’ payments.
- The contract does not provide for control over the end use of the products, making it impossible to prove the legality of the transaction during an inspection.
Result:
a comprehensive conclusion with step-by-step recommendations for the safe execution of the transaction, recommendations on secure payment methods and logistics.
Subscription support
Description:
Ongoing support for the company in matters of sanctions compliance. Includes: regular checks of new counterparties, consultations on current transactions and contracts.
Examples of risks that are monitored on an ongoing basis:
- A new owner or affiliated company of an existing partner has been added to the sanctions lists.
- Restrictions have been imposed on certain services (e.g., consulting, auditing, IT), and the existing contract falls under the ban.
- Changes in export control regulations make it necessary to obtain a licence for goods that were not previously subject to restrictions.
Result:
prompt protection of the business from sanctions violations, timely identification of risks.
Why is sanctions due diligence necessary?
To reduce the risk of blocked transactions and fines.
To ensure business transparency with banks and partners.
To protect the company from secondary sanctions.
To prove that the company exercises a minimum degree of caution and prudence in accordance with OFAC requirements.
FAQ
How long does the check take?
Usually 2 to 10 business days, depending on the amount of information.
What sources do you use?
Official sanctions lists, government registers, international databases and open sources.
Can the report be adapted to the requirements of a bank or investor?
Yes, the format of the report can be further agreed upon.