Representative matter · Sanctions & AML
Sanctions exposure audit for a commodities group
A commodities trading group operating between Asia and the CIS could not say with confidence which sanctions regimes attached to which legs of its business.
- The brief
- Establish the position and fix what needed fixing.
- Our role
- We screened counterparties, ownership chains and payment flows against the applicable regimes and produced a written exposure map with a remediation plan.
- Outcome
- The board adopted the plan; the group's banks accepted the framework at their next review.
Described without identifying parties or amounts. Past outcomes do not predict the result of any future matter.
The practice behind this matter
Where this fits
Practice
Sanctions & AML
Compliance in a neutral jurisdiction: sanctions exposure screening, AML and KYC frameworks, contract review and defence where a dispute has a sanctions element.
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