Which sanctions actually apply to your Hong Kong business?
Sanctions and AML compliance in a neutral jurisdiction: exposure screening, policies, KYC frameworks and contract review for groups operating between Asia, the CIS, the Middle East and Europe.
What we solve
Few areas produce more noise and less clarity. The starting point is jurisdictional and dry: Hong Kong implements United Nations sanctions through its own legislation and does not implement unilateral US sanctions. From there, the questions become specific — who are your counterparties, which banks and currencies does the business depend on, and which rules attach to each leg of each transaction.
We treat this as compliance work: measured, documented, defensible. We screen exposure, write the policies, build the KYC framework and review the contracts, so that the position is clear before a bank or counterparty asks — not after.
What we do
Sanctions exposure screening
Mapping of counterparties, ownership chains, goods and payment flows against the sanctions regimes that actually attach to each leg.
AML / CFT policies
Policies and procedures aligned with Hong Kong's anti-money-laundering framework and the standards banks expect of their clients.
KYC frameworks
Internal know-your-customer programmes for groups that onboard their own counterparties and investors.
Contract review with a sanctions element
Sanctions clauses, compliance representations, suspension and termination mechanics — reviewed before signature, not after a freeze.
Dispute defence with a sanctions element
Defence strategy in contract disputes where sanctions are raised, acting with locally licensed counsel where Hong Kong proceedings are involved.
Neutral-forum contracting
Contract frameworks with HKIAC arbitration clauses for transactions whose parties need a neutral, enforceable forum.
Representative experience
Sanctions exposure audit for a trading group
Screened a commodities trading group's counterparties and payment flows against three sanctions regimes and produced a remediation plan adopted by the board.
AML framework for a private investment office
Wrote the AML and KYC framework for a multi-family investment office onboarding external co-investors.
Defence of a sanctions-based non-payment
Advised a respondent in arbitration where the counterparty invoked sanctions clauses to avoid payment. The tribunal rejected the defence.
Matters are described without identifying parties or amounts. More representative matters.
Partners recognised in Chambers and Legal 500.
Recognition sits with the individuals who run your matter — not with a logo. The partners responsible for this practice are listed in the leading independent directories.
- 01Initial meeting and conflict check, then a written assessment of your situation.
- 02A proposal with a clear fee structure and scope before any work begins.
- 03The matter is run with regular updates and direct partner access.
- 04A result report and a recommendation on next steps.
The team for this practice
Victor Lazarev
Cross-border transactions, English-law deal documents, sanctions and AML compliance.
Marcus Tan
Sanctions and AML compliance, KYC files, regulatory perimeter.
Julian Ferris
Sanctions, AML and compliance in a neutral jurisdiction.
Questions clients ask
Does Hong Kong apply US sanctions?
No. Hong Kong implements United Nations sanctions through its own legislation and does not implement unilateral US sanctions. That is a statement about Hong Kong law, not about banking practice: banks operating in Hong Kong frequently apply group-level policies that reflect US and EU rules.
Both layers matter. We map the legal position and the practical one, and we put the difference in writing.
Is it lawful to work with CIS counterparties through Hong Kong?
It depends on who the counterparty is, what is being traded and how payment flows — which is precisely what screening establishes. We document what is permitted, flag what is not, and decline work that is designed to disguise either.
What AML obligations does an ordinary Hong Kong company have?
Hong Kong's anti-money-laundering legislation directly regulates financial institutions and designated professions. An ordinary trading company is mostly governed by its banks' expectations and by general record-keeping duties — which is exactly where most practical problems arise. We right-size the framework to the business.
Can a contract protect us if sanctions change mid-performance?
It can allocate the risk. Well-drafted sanctions clauses define what triggers suspension or termination, what happens to money in flight and who bears the cost of a freeze. No clause removes the risk; a good one decides in advance who carries it.
Will you help us structure around sanctions?
No. We advise on compliance: what applies, what is permitted and how to document the position. Work designed to evade sanctions is work we decline — which is also why our files survive scrutiny.
How often should sanctions screening be refreshed?
On every new counterparty; on every material change to an existing one — ownership, goods, payment route; and on changes to the regimes themselves. For active trading businesses we set a screening rhythm rather than a one-off check, because lists move faster than contracts do.
What records evidence compliance if a bank or counterparty asks?
Dated screening results, the methodology used, the decisions taken and their reasoning — kept contemporaneously.
A compliant decision without a record is, for practical purposes, indistinguishable from no decision. Building that record is part of every framework we install.
From the Sanctions & AML cluster
Which sanctions apply in Hong Kong — and which do not
Sanctions clauses in supply contracts: allocating the freeze
An AML framework banks will recognise
Practitioner notes for this practice are in preparation and will appear in the Sanctions & AML cluster.
Visit the Insights hubDiscuss a Sanctions & AML matter.
A written assessment of your position and options is the usual first step.