We provide in-depth advice on a variety of issues related to export risk control and sanctions enforcement by the EU, UK, UN, US and other international organizations, ensuring that our clients can safely manage their business in real time around the world.

We help our clients navigate the growing web of various sanctions restrictions and export controls, advising them in their dealings with financial institutions, regulators and government agencies, as well as with international partners.

Due diligence is an important part of every company’s operations, helping to assess the risks associated with its activities and transactions and to avoid problems arising from violations of sanctions and export controls.
Our due diligence includes screening an organization’s existing and potential customers, partners and transactions against global sanctions lists to identify financial risks and ensure compliance with international regulations.

We help clients assess not only direct, but also indirect links to sanctioned persons, as well as identify sanctioned areas and/or products.

We assist our clients in assessing the codes, origin and technical characteristics of products, advise whether licenses are required for the examination of these products or for the client’s activities, and if so, assist in obtaining them. Accordingly, we advise on the documents that need to be submitted to local authorities in connection with export controls.

After the review, we produce written opinions that not only help you better understand potential risks, but also provide guidance on how to manage them, stay within the law and make the right decisions.

If the sanctions screening process identifies a potential risk, an investigation is initiated. The purpose of the analysis is to confirm or refute the potential risk by enriching the customer data and cross-checking it. This step confirms whether the alerts were false or positive and suggests remedies.

All companies must be vigilant about attempts to circumvent international sanctions and participation in circumvention schemes. You should take steps to detect such activity and protect your business from potential sanctions violations by utilizing the tools we offer: screening procedures, internal investigations, verification and monitoring capabilities, open data sources, etc. This may include the use of transactional activity and customer attributes that may trigger the following red flags. No single red flag is necessarily an indication of illegal or suspicious activity, so all relevant facts and circumstances should be considered before determining whether a particular transaction or customer is suspicious or associated with potential sanctions evasion.

We help identify and control risks, thus avoiding both sanctions violations and the usual “over-control” that often results in companies losing some of their customers/partners.

Why is continuous monitoring important for any business?

Sanctions and export control verification should be conducted in several phases to ensure compliance. Initial screening should be conducted at the time of contracting a new customer or partner. Before conducting business, financial institutions or firms should verify the identity of their customers or partners against the relevant sanctions lists and their possible indirect links to sanctioned persons. This step ensures that a legal or natural person is not prohibited from engaging in certain activities. Products and/or services should be verified accordingly.

However, it is not sufficient to conduct such due diligence only at the beginning of a business relationship. It should be conducted regularly throughout the life cycle of the relationship with customers and partners. This is because the status of sanctions and export controls can change over time. A customer, partner, or product/service that is not subject to sanctions and export controls at the time of initial verification or initial risk assessment may be subject to sanctions at a later stage.

The criteria for compliance with sanctions and export controls are complex and ever-changing, requiring knowledge of a wide range of international and EU legislation, and are not easy to comply with efficiently and effectively.
Not only do government regulators and law enforcement agencies require companies to have sanctions programs in place, but financial institutions, business partners and customers are increasingly demanding that companies have robust sanctions risk management programs in place. EU authorities also expect all companies to have robust sanctions compliance programs built into and used by their operations.
To help our clients adopt a comprehensive approach to risk management, we help them develop long-term solutions to effectively manage the risks of today and tomorrow, from training and developing staff to implementing strong organizational structures that can withstand internal and external controls and audits.

The following are the key components of an effective sanctions compliance program:

• Leadership Commitment;
• risk assessment;
• Policies, procedures and internal control training;
• and Audit.

Sanctions and export control compliance programs should be risk-based and proportionate. What works for one organization may not work for another, and enforcement authorities have noted that the appropriate sanctions compliance program depends largely on factors specific to each organization (including its products, customers, and the nature of its business).

We help our clients implement a program that includes all the necessary components and is tailored to their specific business model and needs.

We work with companies that develop and implement sanctions and export control compliance programs, which allows us to offer a very broad range of services.

Every enterprise needs to have well-developed, detailed, and clear internal policies and procedures so that every employee knows and understands the company’s sanctions policy and what he or she must do on his or her part to avoid violating sanctions and export controls. In the absence of such clear and understandable documents, a company manager will be held liable for the unlawful actions of any employee at any level of the company.

To avoid such situations, we help our clients:

• Develop internal policies, procedures, and controls to comply with international sanctions and export controls;
• Analyze and help improve existing policies, procedures and controls.

As sanctions have been tightened, the customs authorities of EU Member States have tightened controls on exports of sanctioned goods to third countries. The number of pre-trial investigations launched in connection with sanctions violations is increasing.

Export controls also verify the legality of trade in military and dual-use products and technologies. “Dual-use goods” are goods and technologies that are primarily used for civilian purposes but may be used for military purposes and are therefore subject to restrictions or controls.

As part of export control consultations, we assess the risks of working with dual-use goods: business model assessment, the need to obtain permits and licenses, partner screening.

Sanctions and export control verification procedures will only be effective if everyone in the company understands how to apply them and knows what actions they must take within their area of expertise to ensure that sanctions are not violated.

We provide training tailored to the level of employees and the specifics of a particular company’s business. We organize training according to the client’s needs (live, remote, via relevant platforms, etc.)

Our professionals prepare legal documents, expert reports, and opinions related to the imposition and enforcement of sanctions, providing a comprehensive analysis of the matter based on applicable statutes, case law, and other documents gathered during the investigation.

These documents, prepared by our experts, are used by clients in their dealings with financial institutions, government regulators and partners as proof that, for example, the company is not associated with sanctioned persons, is not subject to relevant regulation, etc.

To address important issues such as food security in third countries, etc., the EU sanctions packages provide derogations to lift the asset freeze and provide funds and economic resources to certain individuals who, prior to their listing, played an important role in international trade in agricultural and food products, including wheat and fertilizer.

In order to avoid circumvention of sanctions, national competent authorities are mandated to conduct a case-by-case assessment, taking into account each individual transaction involved.

We assist our clients in assessing the possibility of derogations and/or exemptions, and in formulating and liaising with national authorities to ensure that appropriate licenses and exemptions are granted.

We represent our clients before national, European and international institutions in connection with sanctions and enforcement matters.