With many international companies withdrawing activity and operations from Russia, Nabi Abdullaev and Henry Smith discuss recommendations for international companies operating in countries with high political risks.
Expertise to support your sanctions compliance
Sanctions regimes led by the US and mimicked by other governments generate risks and compliance challenges for banks, companies and investors. Sanctions are often justified by these governments to support and uphold values they seek to promote in their foreign policy, but are also used to force political outcomes.
Our experts have a unique blend of skills, with extensive experience in political risk, compliance, due diligence and forensic investigations. Control Risks is here to support you and your organisation’s legal and compliance counsel in considering your sanctions compliance.
Country risk assessments and monitoring
Control Risks can help you perform country-level assessments on the focus, breadth and enforcement history of sanctions, and advise on how to do business in the countries where sanctions regimes have recently been relaxed.
Investment and counterparty due diligence
We deliver pre-relationship and pre-investment due diligence into the ownership and control of specific entities, their operations and leadership, and any important or higher risk suppliers and clients, including assessments of the vulnerability of an entity or individual of being sanctioned in the future.
We can also support your expansion in sanctioned countries by mapping sanctioned entities’ business interests in a country or a sector, allowing you to proactively control your exposure to them. We provide assessments of the implications of existing third parties being designated as sanctions regimes evolve, with advice on how to react in your specific business context.
Investigate and resolve problems and crises
Control Risks can investigate sanctions breaches through a variety of techniques. We manage these investigations on behalf of banks, corporates and investors, typically working with their external legal and compliance counsel.
- Data analytics
- Digital forensics
- Document review
- Investigative interviews
- Business intelligence and due diligence
- Data collection and hosting
We also advise on and implement remedial steps to improve sanctions compliance following an investigation.
Improve governance and compliance processes
Control Risks' in-house experts can develop and implement sanctions compliance programmes that are built on guidance from governments and lessons learnt from enforcement cases relevant to your industry. This includes the core components included in the US Department of Treasury’s Office of Foreign Asset Control’s recommendations on how to develop a sanctions compliance programme.
We can monitor changes to the focus, breadth and enforcement of sanctions across a portfolio of countries. We can also develop third-party due diligence programmes suited to identifying ownership and control structures, along with proactive monitoring of third-party data to identify connections to sanctioned entities or countries.
Navigating Sanctions Regimes infosheet
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The latest edition of our biennial global analysis report Navigating the global sanctions landscape examines what drives countries’ sanctions policies, emerging issues such as cryptocurrency and ransomware, and the role of sanctions risks in transaction diligence and third-party management.
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Foreign companies in the South Caucasus and Central Asia should consider whether regional partners or offices are involved in sanctioned business activities.
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