Navigating the global sanctions landscape in 2020

Diverging paths, increasing risks

October 2019

controlrisks.com Sanctions report Sanctions report

Table of contents

The global sanctions landscape in 2020 01

Sanctions risk map 05

How can companies manage their compliance with increasingly complex sanctions? 09

Five countries to watch in 2020 11 Iran 13 North Korea 15 Russia 17 Venezuela 19 Syria 21

Beyond sanctions: Foreign investment considerations 23

About us 24

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The global sanctions landscape in 2020

Sanctions regimes are increasingly Middle East and Asia-Pacific to pursue under US sanctions.1 Partly, this complex and less predictable. US more independent policies to grow reflects Trump’s more unilateral foreign policy under President Donald their own spheres of economic and and nationalist approach to foreign Trump has become markedly more political influence. policy. Geopolitical dynamics protectionist under his “America First” have also made it increasingly There are five key trends shaping mantra, emphasising geopolitical difficult for the UN Security Council global sanctions risks: competition and stark pursuit of to adopt collective sanctions national interests. Growing polarisation 1. The US is introducing and enforcing against governments – think of between the presidency and sanctions more frequently. Syria, for example – that enjoy Democratic-controlled Congress has Sanctions have been perceived the protection of Russia or China. also resulted in more personalised as a low-cost and low-risk foreign However, while the US can afford and contested policy outcomes. policy tool since the Barack to impose unilateral sanctions US relations with traditional allies Obama administration, but that has because of the centrality of the (particularly in Europe) have deteriorated become much more acute under US dollar to the global financial amid disagreement over a suite of President Trump. The US is also system and commerce, their lack of strategic issues, including sanctions making extensive use of so-called international legitimacy and buy-in on Iran and Russia. Meanwhile, secondary sanctions aimed at complicates their implementation US and European retrenchment is pressuring non-US companies and antagonises the US’s allies. encouraging regional powers in the to stop business with countries

Source: The U.S. Department of The Treasury (https://www.treasury.gov/resource-center/sanctions/CivPen/Pages/civpen-index2.aspx)

Fig.1 The numbers: OFAC enforcement actions by year (2011-2019)

1.4 30

1,2 25 1.0 20 0.8 15 0.6 10 0.4 0.2 5

0 0 2011 2012 2013 2014 2015 2016 2017 2018 2019

Cases Cases (non finance) Fines (USD billions)

1 Primary sanctions are restrictions applied to US persons, while secondary sanctions apply to non-US persons and are designed to prevent non-US persons from doing business with a target of primary US sanctions. They have mainly been used in connection to Iran, North Korea and most recently Venezuela. There is very limited precedent for the enforcement of secondary sanctions. However, the prospective penalties that secondary sanctions could impose on non-US organisations is often enough to encourage compliance with them.

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4. The US is encouraging its allies enforce these measures, and US responsible for or complicit in to adopt their own sanctions. sanctions regimes will probably human rights violations or – notably Gulf states have joined this trend, continue to be the most relevant for – corruption. Five other countries developing blacklists of their own. businesses operating in the region. – Canada, Lithuania, Estonia, While most of these are designed International financial hubs (such Latvia and the UK – have since to target terrorism financing, others as Switzerland, Hong Kong and passed similar provisions, with the are driven by foreign policy aims. Singapore) have also traditionally EU and Australia also considering For instance, the Terrorist Financing maintained independent sanctions proposals along these lines. While Targeting Center (TFTC), which regimes to counter terrorist financing, these measures have had only comprises the US, Bahrain, Kuwait, money laundering and other limited direct impact on business, Oman, Qatar, the UAE and Saudi transnational threats, though these designations will not remain static Arabia, in May 2018 imposed are mostly aligned with the UN. and will continue to reflect human sanctions against the leader of rights and corruption investigations, 5. Extraterritorial sanction regimes the Lebanese Shia movement as well as broader geopolitical are proliferating. Extraterritorial Hizbullah, Hassan Nasrallah, considerations. Being able to better regimes that apply to persons in and other entities and individuals assess the likelihood that a current countries not otherwise subject affiliated with the movement. These or prospective business partner to sanctions are likely to continue are intended to counter Hizbullah’s will feature on a Magnitsky list in to spread. The US was the first political power in Lebanon and the future will allow organisations country to adopt sanctions to reduce Iran’s influence across the to make more informed, forward- punish human rights abuses (the Middle East; Hizbullah is widely looking decisions about new Magnitsky Act in 2012, which viewed as acting as an Iranian business relationships. targeted Russia specifically), and proxy. However, Gulf countries 2. There is disagreement within 2017 enacted the Countering US also disagree on the targets for in 2016 it expanded their reach are still building the capacity to the US on the use of sanctions. America’s Adversaries Through sanctions, which means companies to any foreign nationals deemed Policymaking under Trump often Sanctions Act (CAATSA) over now need to comply with two sets shows differences between Trump’s objections, and then tried of blacklists. The EU has sought the president’s intentions and to prevent him lifting sanctions to save the nuclear deal since members of his administration and on Russian company Rusal this the US withdrawal by updating the Republican Party. This political year. Conversely, Congress also its Blocking Statute (to forbid EU polarisation in Washington means wants more sanctions on Saudi entities from complying with US that significant differences over Arabia but is split over sanctioning sanctions on Iran and to allow sanctions policy exist between Europe for the Nord Stream gas them to recover any associated Authors: the Trump administration and pipeline from Russia. Congress damages) and setting up a special Congress, particularly after the is generally aligned with the purpose vehicle (the Instrument opposition Democrats’ gains in administration behind Iran and for Supporting Trade Exchanges, the November 2018 midterm Venezuela sanctions. or INSTEX) to enable certain election. In short, Congress is transactions with Iran. However, the Henry Smith 3. The EU and US are growing trying to “codify” sanctions – or bloc has been unable to offset the Sorana Parvulescu Partner apart on sanctions policy. require Congressional review – to impact of US secondary sanctions; Senior Partner Compliance, Forensics, Divergence between Trump’s US make them more difficult for the EU businesses will not risk their Global Risk Analysis and Intelligence and key European allies on major administration to remove. This relationships and businesses in the foreign policy issues – above all, more aggressive stance shows US for Iran. Over the longer term, Iran – is increasing sanctions risk Congress trying to regain control the EU will be looking to increase and complicating compliance for over foreign policy, after having its economic autonomy from the companies. The US’s exit in May delegated much of it to the White US, including through its own use 2018 from the nuclear deal has Jonathan Wood House over the decades. The of sanctions and measures that exposed EU companies to sector Director division has been stark when it give the euro currency a greater wide US restrictions. The EU or Global Risk Analysis comes to Russia: Congress in role in international trade.

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Sanctions risk map

Methodology Control Risks’ CORE country risk experts evaluated sanctions risk according to the ability of companies to operate in compliance with applicable sanctions regimes, primarily, UN, US and EU but also third-country sanctions (where relevant). It encompasses the focus and breadth of sanctions which may apply to multinationals doing business in the country, and also considers broader implementation and enforcement trends (particularly at the US and the EU levels). Additionally, the ratings reflect the underlying geopolitical, political, security and integrity factors driving sanctions risk in the country, and the likelihood of applicable sanctions regimes being strengthened or relaxed as a result. In time, our CORE country risk experts will expand this analysis to cover a broader spectrum of risk ratings.

Sanctions risk ratings – definitions

Risk rating Definitions

Extreme Sanctions risks severely limit investment or operations in most sectors of the country, and pose critical compliance, reputational and operational risks to business. For example: Comprehensive UN, US, EU and third-country sanctions apply, including arms and trade embargoes. Sanctions enforcement, particularly from the US and the EU, is very strict and proactive. There is widespread support within the international community for sanctions, on grounds that the country’s behaviour significantly transgresses international norms and/or poses significant threats to global and regional security.

High Sanctions risks greatly hinder investment or operations in most sectors of the country, and pose significant compliance, reputational and operational risks to business. For example: Sectoral sanctions restrict or prohibit transactions with specific economic sectors. Trade sanctions ban the provisions of certain goods or services, including arms embargoes. Targeted UN, US, EU and third-country sanctions apply to significant groups of individuals or entities with interests in the economy. Sanctions enforcement, particularly from the US and the EU, is strict and proactive. There is generally strong support within the international community for sanctions, on grounds that the country’s behaviour significantly transgresses international norms and/or poses significantly threats to global and regional security.

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Fig.2 Sanctions risk ratings Medium and low risk countries not depicted

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How can companies manage their compliance with increasingly complex sanctions?

Source: The U.S. Department of The Treasury (https://www.treasury.gov/resource-center/sanctions/CivPen/Pages/civpen-index2.aspx)

Fig.3 The numbers: OFAC enforcement actions by sector (2011-2019)

Financial services 47 Manufacturing 15 Information, communication and technology 15 Pharmaceuticals and healthcare 10 Grand Total Oil and gas 14 Logistics and transport 7 Retail trade and luxury goods 6 FMCG 5 Insurance 5 Other 23

1. The US and the EU have given Clear management support and buy-in The EU has also published due you guidance to follow. The US for sanctions compliance diligence guidance for companies sanctions enforcement agency, the considering whether and how to The importance and centrality of Office of Foreign Assets Control undertake due diligence on business risk assessments to understand and (OFAC), released its sanctions opportunities in Iran. This takes evaluate your exposure compliance programme (SCP) organisations through a series of guidelines in May 2019, which The development of internal controls potential transactions, assessing the coincided with one of the biggest to address the risks that you face level of risk and recommending a annual sanctions conferences in commensurate level of due diligence. Testing and auditing these controls, Washington, DC. The guidance and responding to any shortcomings 2. You should monitor enforcement is consistent with previous actions. OFAC publishes its advisories released by other US Training on sanctions compliance enforcement actions on its government agencies about processes for different sets of website with a helpful summary financial crime compliance, most employees. of the nature of the violation, the notably anti-bribery and corruption. OFAC has made it clear that the decision-making process it went The guidance recommends five presence and application of a SCP will through to determine the severity pillars as central to a sanctions be taken into consideration when it of the penalty, and – increasingly – compliance programme: considers enforcement actions. commentary on the nature of the

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compliance commitments that the their sales and marketing activities, a legal review of your exposure organisation has made in response can expose them to sanctioned points and establishing the ultimate to the enforcement action. These countries and trigger violations. beneficial owners and controllers enforcement actions are a rich and We have seen this in several cases of your counterparties. There is concise source of guidance for with clients in recent years. OFAC’s limited guidance from government people responsible for sanctions designations of companies and agencies about how far your due compliance, which we monitor on individuals as sanctioned entities diligence should go to consider behalf of clients. They can help also demonstrates how countries your immediate counterparties’ you understand how sanctions like Iraq and the UAE can be used customers and relationships. In our violations occur, how OFAC by networks seeking to circumvent experience, a risk assessment of interprets companies’ practices and sanctions. Your third-party risk a relationship or transaction you behaviours towards compliance, and due diligence assessments are considering, and identifying and the types of remedial steps that of agents, distributors, suppliers your blind spots, is typically a good organisations are encouraged to and clients in countries that trade starting point for determining the adopt to improve their compliance or share borders with sanctioned level of due diligence you should processes. It can be helpful to use countries should specifically apply. Having done your initial due these actions to build your business address your exposure to sanctions diligence and risk assessment, you case for adjustments to your from these entities. Not knowing then need to ensure that any red Five countries to watch organisation’s existing practices their business activities is not a flags that required remediation are and to develop typologies and case good defence. addressed and monitored. in 2020 studies in training sessions. 4. Your due diligence needs to go 5. You need multi-disciplinary 3. You should understand your deeper than your immediate teams to understand and sanctions risk in countries that counterparties. Recent OFAC monitor sanctions risk. Sanctions are not sanctioned. OFAC’s enforcement actions demonstrate have a crucial difference from guidelines specifically point out that the need to consider sanctions other financial crime regulations a good SCP should be designed to exposure throughout your value chain that companies need to comply prevent employees from engaging – suppliers through to customers with. Sanctions are a foreign policy in misconduct. The frontline and everything in-between. tool subject to a range of political, staff responsible for growing Furthermore, the political security and economic drivers that your business will be aware that messaging from representatives other financial crime regulations are countries like North Korea, Iran of the US Departments of not affected by. As such, we see and Syria have sanctions and Treasury and State under the companies and financial institutions compliance challenges. However, Trump administration has called increasingly approaching sanctions your colleagues might not always on companies to consider their risk assessments and monitoring think the same way about countries customers’ customers in their due with a broader range of skill that trade with sanctioned diligence and risk assessments. sets and disciplines. Legal and countries, like China (with North Although there is not a prescription compliance teams benefit from Korea) or Turkey (with Iran), but that to do this in OFAC’s guidelines the insight and understanding are not sanctioned jurisdictions. for a SCP, the political tone of politics and diplomacy that Recent OFAC enforcement has been made clear by the government affairs and political risk actions and our own due administration. In our experience teams can bring. diligence experience indicate that with clients, sanctions compliance organisations’ supply chains, and due diligence will typically include

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Iran

Outlook What to watch Implications EU and UN sanctions on Iran remain Triggers for increasing sanctions risk: Companies with US interests/ lifted as a result of the implementation exposure will most probably choose Other signatories to the JCPOA of the Joint Comprehensive Plan of to continue to comply with US withdraw from the agreement, which Action (JCPOA) in January 2016. primary and secondary sanctions. effectively collapses. However, sanctions risk increased The EU’s countermeasures are sharply with the US’s withdrawal from Iran produces enough fissile material unlikely to encourage – or force – the JCPOA in May 2018, which led to to approach nuclear weapon European companies to do business the re-imposition of US primary and “breakout” thresholds. with Iran beyond humanitarian- secondary nuclear sanctions in August Significant security incidents by related business. and November 2018. The US in 2019 Iranian proxies against US assets or also increased its sanctions regime as However, legal disputes in Europe personnel in the Gulf. part of its “maximum pressure” policy. are likely to question the application The growing burden posed by US Fresh satellite or ballistic missile and validity of US secondary sanctions on various sectors of the launches suggesting technological sanctions, and award damages Iranian economy means that Tehran’s advances. from non-US companies that have chosen to comply with US incentives to comply with the nuclear Russia supporting China in its trade secondary sanctions. agreement have diminished. Iran will war with the US. increasingly breach the nuclear deal Companies that have the legal space over the coming months to pressure and risk appetite to engage Iran will the EU into offsetting the impact of US Triggers for decreasing sanctions risk: still face a range of practical and sanctions on its economy, and to give operational challenges, principally itself concessions it can offer to the The US and Iran engage in direct around banking and insurance. US in return for temporary sanctions diplomatic talks, with a view to relief and a return to negotiations. The negotiate a new nuclear deal. EU is unlikely to systematically target US agrees not to enforce aspects of Iranian persons and entities over the its secondary sanctions for EU trade, next year, with its efforts focused and/or establishes some sort of on how to retain or reformulate the cooperation around due diligence. JCPOA. However, the EU’s position will be contingent on the extent of Iranian compliance with the JCPOA, though we expect Iran to remain in large part compliant with it.

Daryll O Hanlon Senior Consultant, Compliance, Forensics and Intelligence

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North Korea

Outlook What to watch Implications International sanctions have expanded Triggers for increasing sanctions risk: Amid hopes for a US-North Korea significantly since 2016 in response to nuclear deal and the possibility of A breakdown in US-North Korea Pyongyang’s unprecedented nuclear sanctions easing, business interest in nuclear talks, amid long-standing, and ballistic missile tests in 2016-17. the North is tentatively emerging. incompatible positions on The US under Trump has pursued a denuclearisation. However, business deals with North strategy of “maximum pressure” and Korea – even indirect ones – will has strengthened economic sanctions. A resumption of long-range ballistic continue to involve very severe risks, However, diplomatic engagement missile and nuclear tests by the North. including operational, non-payment between North Korea, the US, South and reputational risks. Korea and China since early 2018 has the potential to reduce sanctions Triggers for decreasing sanctions risk: risk over the next three to five years. Historic US-North Korea deal While existing sanctions are being based on “phased” approach enforced less strictly, a formal and full to denuclearisation in return for lifting of UN, US, EU and third-country sanctions relief. sanctions will take much longer – at least some significant sanctions will remain in place until the North has made very substantial concessions. A highly fragile diplomatic process lies ahead over the next year, with a persistent threat of breakdown and re-escalation.

Julia Coym Senior Analyst, Global Risk Analysis

Courtney Zhou Associate Consultant, Compliance, Forensics and Intelligence

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Russia

Outlook What to watch Implications Sanctions risk emerged in 2014 over Triggers for increasing sanctions risk: In the absence of new sanctions laws Russia’s annexation of Crimea, and massive implementation against Revelations of new evidence of involvement in the eastern Ukraine major businesses, the investment Russian interference in elections in conflict, military intervention in Syria, and appeal of Russia somewhat the US in 2020. domestic human rights and corruption improves, compared with 2014-16. issues that escalated after Moscow’s Revelations of malicious cyberactivity Companies with a significant interference in the 2016 US election. in the US and an allied country, presence in Russia have had enough However, the sanctions regime has attributed to Russian state actors. time to adjust their compliance to largely stabilised in the past two years. Another attack against a Russian stable sanctions risk. Russia is refraining from moves that defector or anti-regime figures in could trigger new sanctions and/or more Russia’s countersanctions and import Europe or the US. robust implementation of existing ones. substitution policies have eroded in Trump is under sustained bipartisan Rupture of personal rapport between many sectors, leading to lucrative pressure from Congress to strike a Trump and Putin. opportunities for international companies with a sophisticated hardened stance on Russia ahead of the Russia supporting China in its trade understanding of sanctions risk. 2020 election but continues to oppose war with the US. more draconian sanctions as limiting his Companies with less exposure to US flexibility to manage US foreign policy sanctions risks, primarily Chinese, towards Russia. The failure of the Mueller Triggers for decreasing sanctions risk: Japanese and Korean entities, as well report to tie Trump’s 2016 victory to as ones from the Middle East, have an Russia’s meddling, internal strains on the A durable de-escalation in the advantage over their US and European EU’s readiness to roll over sanctions and conflict in eastern Ukraine, in line peers on the Russian market. the lack of clear vision for post-conflict with the Minsk-2 peace agreement. Syria have further de-incentivised new Trump’s victory in the 2020 Relatively stable US-Russia relations sanctions against Russia. The poorly presidential elections, which would under Trump may quickly come to an calculated effect of sanctioning Rusal, push the Moscow meddling narrative end, with sanctions risk increasing, which resulted in the effective revocation away into the past. if a new administration comes to of sanctions under pressure from US power in Washington in 2020-21. domestic and international business lobbies, is also contributing to the US administration’s unwillingness to press sanctions against major Russian businesses. Within the EU, while member Nabi Abdullaev states are still broadly in agreement Director, over sanctions adopted in response Compliance, Forensics, to Ukraine events, they demonstrate and Intelligence preparedness to ease the most substantial of these sanctions if progress is made resolving the conflict in the east Alexey Eremenko of the country. We do not anticipate Senior Consultant, a major breakthrough in the eastern Compliance, Forensics, Ukraine conflict over the next year. and Intelligence

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Venezuela

Outlook What to watch Implications The US since mid-2017 has Triggers for increasing sanctions risk: US financial sanctions have made significantly expanded its sanctions it difficult or prohibitive for many US Maduro holds highly fraudulent regime against Venezuela, imposing companies to continue operating congressional elections in 2020. wide-ranging targeted, financial and in Venezuela. However, US oil sectoral sanctions. Targeted EU and The Maduro regime jails Guaidó, or companies continue to operate third-country (for instance, Canada) other members of the US-aligned under sanctions waivers. sanctions also remain in place. opposition. More importantly, sanctions merely Sanctions risk increased further after Venezuela finds ways to circumvent add to Venezuela’s complex and National Assembly President Juan sanctions with the help of allies such hostile business environment, in Guaidó in January 2019 declared as Russia, China and Turkey. which the Maduro government himself interim president and called has increasingly intervened to for new elections. In the most maintain control over aspects of restrictive measure intended to force Triggers for decreasing sanctions risk: the economy. Reputational risk regime change, the US in January will remain high as the Maduro 2019 imposed targeted sanctions on Maduro is forced to step down by a government stays in power. state-owned Petróleos de Venezuela critical mass of his own armed forces (PDVSA), though it issued – and and leftist allies. then renewed in July 2019 – waivers A successful coup ousts the for five US companies. International Chavista regime and puts the pressure on the regime of President opposition firmly in control of the Nicolás Maduro will persist, raising government. the likelihood of further sanctions from the US as well as the EU and third countries. The Trump administration is betting that tough sanctions, without military intervention, will dislodge Maduro and is thus likely to continue to tighten sanctions. The US retains several options for further sanctions escalation, in the form of additional secondary sanctions or an embargo similar to that imposed on Cuba that bans all US companies from operating there. However, tougher US sanctions on Venezuela will likely include waivers for the US oil companies that are keen to remain in the country. The US government is also unlikely to force Western oil companies out because that would Raul Gallegos hand over control of the oil sector to Director, Chinese and Russian companies. Global Risk Analysis

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Syria

Outlook What to watch Implications Targeted UN and sectoral US, EU and Triggers for increasing sanctions risk: Doing business in Syria exposes third-country sanctions continue to companies to a series of overlapping Fresh evidence of the Assad preclude most business activities from sanctions regimes beyond those regime’s use of chemical weapons US and European companies in Syria, applied to the Assad government. and involvement in other war crimes. even as the security environment is This is because of the presence of likely to become more conducive to Iranian, Iraqi, Lebanese and Russian business – particularly reconstruction business interests that are subject to Triggers for decreasing sanctions risk: work. However, these sanctions are their own sanctions regimes. very unlikely to be relaxed if President Regime change that leads to the Beyond sanctions risk, companies will Bashar al-Assad remains in office, installation of a political leadership also face reputational risks if they are which is the most likely outcome given amenable to Western countries. perceived as legitimising the actions reduced US support for opposition The EU and US come to a pragmatic Assad took during the conflict. groups and Russia and Iran’s realisation that they will be better Comprehensive sanctions regimes continued military and political support able to exert influence in Syria and have provoked fuel and other for him. Assad is likely to further that they would otherwise lose shortages, as well as a broader consolidate his position over the next business and other opportunities economic turndown. These year, ensuring he remains in power unless they eased some of their issues, combined with decrepit during any post-conflict transition. The restrictions. US will also maintain intent to sanction power, telecommunications and Syria as a secondary means to apply other infrastructure, will also pose economic pressure on Iran, which has operational risks to companies backed Assad throughout the conflict. looking to re-enter Syria. More broadly, a general breakdown in the rule of law means that militia and militant groups operate checkpoints, or control the movement of goods or people and natural resources to extract profit – in turn hindering operations in various parts of the country.

Andrew Freeman Analyst, Global Risk Analysis

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Beyond sanctions: Foreign investment considerations

Focus on the Committee on Foreign Investment in the United States (CFIUS)

National security concerns around foreign direct investments (FDI) are a growing concern for multinational companies and their legal advisors the world over. As the global threat landscape continues to evolve, matters including cybersecurity vulnerabilities, dual-use technologies with civil / military fusion, intelligent (information) warfare, and global supply chain considerations are increasingly being monitored and scrutinized in the context of foreign direct investments (FDI) for possible national security concerns, and the respective risks and opportunities they create. Savvy global investors are advised to keep an eye on The Committee on Foreign Investment in the United States (CFIUS) and other foreign investment regulations that continue to develop to ensure their investments can stand-up against growing scrutiny now and in the future.

Risk on the rise The Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) has created a new reality for US companies and foreign investors partaking in transactions focused on critical technologies. On September 17, 2019, the Department of Treasury released draft regulations to implement the changes that FIRRMA made to CFIUS’s jurisdiction and processes. These changes represent a significant expansion of authority and were necessary to address the evolving national security threat environment, particularly the risks inherent in Technology, Infrastructure, and Data (“TID”) US Businesses. While the updates present a more complex regulatory environment, the release of the draft regs provides needed clarity for companies and investors to understand and adjust to the current state of play. Successful models and deal-making strategies will account for the nuance of an evolved security and technological environment, while recognizing the need to engage early and aggressively to address potential national security concerns. Learn more about CFIUS and FIRRMA here.

John Lash Principal, Compliance, Forensics, and Intelligence

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About us

Control Risks exists to make our clients succeed. We are a specialist risk consultancy that helps to create secure, Our experience with sanctions compliant and resilient organisations in an age of ever-changing risk. Advised a chemical company on their Developed a bespoke database that how tighter international sanctions Control Risks’ 3,000 employees work out of 36 offices around the world with experience in 178 countries and 18 sectors. exposure to the shareholders of a detailed key global (UN, EU and could affect their business with Iran With experts strategically placed around the world, we have a unique blend of skills and local insights to support our Russian partner; the nuances of US) and third country sanctions and how to mitigate the associated clients and their legal counsel as they consider sanctions globally. entities part-owned by sanctioned regimes on dozens of countries of sanctions risk. individuals; and the risks of commercial interest to a Mapped a businessman’s corporate Contact us for more information about our experience with sanctions and how we can help you. secondary sanctions for similar multinational chemical company. interests to identify ties to senior and companies. Delivered information at regular sanctioned figures inSyria . During risk-based intervals, with Delivered a country risk assessment our project, sanctions were imposed supplementary consulting and and multiple enhanced due against the subject and one of his monitoring of significant political or diligences for a multinational bank companies. We then assessed the legal developments which could considering whether to finance a risks of sanctions being expanded to impact the client’s exposure. multi-billion-dollar transaction with include the subject’s other companies Such developments included Copenhagen Iran under an OFAC licence. and extended family. Moscow international conflict, unrest, human Amsterdam London Berlin Investigated the sale of electronics rights violations, and proposed or Forensic data analytics to identify Frankfurt Paris in North Korea on behalf of a pending legislative changes. sanctioned individuals and entities in Chicago Zurich New ork Beiing Washington DC Japanese client. Advised on our client’s financial and sales data as Erbil Seoul Tokyo Conducted an assessment of the oil Los Angeles Islamabad Baghdad potential sanctions considerations part of a forensic investigation into Houston Basra Shanghai output implosion in Venezuela and Al Khobar Delhi and provided recommendations for potential sanctions violations in Abu Dhabi Dubai Hong Kong how oil production is expected to Mexico City export controls enhancements. multiple countries. Mumbai be impacted by tighter US

Panama City Lagos Mapped the business interests of sanctions in the future. We identified the historical changes in Bogot Port Harcourt Singapore major sanctioned entities in Iran’s shareholding structure of a company Nairobi Provided a nuanced assessment of consumer goods sector, enabling a in Myanmar to identify the sanctions Jakarta sanctions, their applicability and client to place informed restrictions risks that our clients might inherit political motivations for a Japanese Control Risks office on marketing and sales activities through an acquisition. Forensic collections hub Sao Paulo conglomerate. The client then Data centre location Johannesburg of distributors. formulated a strategy that serves as Control Risks office Sydney Advised an international oil Forensic collections hub the foundation of a sanctions-related company on the likely future policy in Russia. Control Risks office sanctions the US and the Data centre location Conducted a scenario planning international community will exercise for a manufacturing implement against Venezuela. multinational that included a view of

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Notes

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