Today companies are increasingly required to comply with sanctions regulations in the jurisdictions where they conduct business. The sanctions landscape is changing rapidly and to understand it can be a true challenge for companies and financial institutions operating in markets impacted by EU,UN, US and the UK sanction regimes.
Our sanctions due diligence helps clients to understand the risk profile of the third-party and mitigate their risk exposure to existing or potential sanctions. It takes into account the frequent changes to existing lists as well as the differences between the EU, UN US and the UK sanctions regimes. Particular focus is given to ownership of companies with opaque ownership structures and the risk of indirect sanction exposure. Our approach is risk-based and takes into consideration shifts of sanction risks as a result of introduction of new types of restrictions, political developments and other contextual changes. We support our clients’ response to the fast-changing circumstances and managing direct and indirect risk exposure to sanctions in the most effective manner.
An Italian company established that there were indications that one of its suppliers, a German trader of mechanical components, was involved in business operations in Iran, in violations of economic sanctions against the country.
Analysis and enquiries with on-the-ground sources did not identify any sanctions risk factors in relation to the company’s shareholders or the managers. However, the investigation revealed that the company was selling its products, through a long chain of Turkish and Azerbaijani companies to Iranian companies directly or indirectly controlled by the local government.
Based on these results the client took a risk-based decision and ended the relationship with the German supplier.
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