Cis & Caucasus

CRW has undertaken numerous assignments, from standard due diligence to more-complex investigative projects, in Russia, other countries in the Commonwealth of Independent States (CIS) and Armenia. All assignments are conducted in collaboration with experts who have lived and worked in the risk-consulting sector in CIS countries and are fluent in the relevant languages.
Given the complex and fast-changing regulatory framework since Russia has been impacted by UN, US and EU sanctions regimes, the focus of our projects has been on providing risk assessment of the sanctions risk exposure of clients who have business relationships with natural and legal persons from Russia and Ukraine.
Case Study

Integrity due diligence on a bank in a CIS country

An international financial institution intended to enter into a business relationship with a bank in the Ukraine.

The Context

Indications of involvement in corrupt practices created cause for concern. CRW undertook a systematic analysis and enquiries with an extensive network of sources in the country and the broader region. The work uncovered that the bank had improved its governance in recent timets, but confirmed the existence of past episodes of involvement in money laundering and fraud, links to sanctioned subjects and opaque relations with PEPs.

The Result

Based on our risk assessment the client was able to take a risk-based decision and mitigate the risks identified.

Case Study

A Caucasian bank owned by a Russian businessman

An investment fund intended to enter into a business relationship with a Caucasian bank and asked CRW to assess its reputational profile.

The Context

Analysis and enquiries identified multiple violations of anti-money laundering legislation and it was established that the bank’s beneficial ownership was not transparent and the source of wealth of the alleged UBO was a cause for concern. In addition, there was reason to believe that the UBO and, therefore, indirectly the bank, had an elevated sanctions risk exposure.

The Result

Based on the results of the investigation, the client decided not to pursue a business relationship with the bank.

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