Sanctions control and ownership research is a deep dive into an organization’s ownership structure to determine how great a stake a sanctioned party may own in it. This type of research aims to determine if a sanctioned party controls an organization through ownership stakes (direct or indirect)...
Potential futurede jurecontrol:where the alleged controller has no current legal right of ownership or control, but has the legal means to obtain it at a later stage (e.g., an option agreement, a forward contract, etc.). Potential futurede factocontrol:where there is a good reason to bel...
Sanctions control & ownership Understand what subjects are owned or controlled by a sanctioned entity or individual. Our specialist research team has identified more than 49,000 companies owned or controlled by individuals, entities or regions sanctioned by OFAC, the EU, the UK, and seven other ju...
under certain circumstances, extend to entities “owned or controlled” by DPs. To date, there have been few—and at times partly contradictory—English court cases addressing the “ownership and control” criteria under the UK sanctions regime. The latest judgment inHellard v OJSC Rossiysk...
The challenge is exacerbated by variances in different regulatory approaches to sanctioned ownership and control across jurisdictions. In the US, the threshold for identifying sanctioned ownership of an entity is set at 50% or more, whereas in the EU, it’s defined as more than 50%, a subtle...
This is a formidable task for many businesses who will need to approach sanctions risks on many levels: from technical expertise on the movement of certain goods, the complicated due diligence of control and ownership structures, to grasping fluid and divisive geopolitics that drive changes to ...
Ownership and control: Does the designated person own, hold or control, directly or indirectly, more than 50 percent of the interest in the entity being serviced? Can the entity be considered in some other way to be controlled by a designated person? Assets: What precisely are the assets of...
In June 2022, EuroChem issued a “statement on ownership and control” following reports that Andrey Melnichenko had ceded ownership in the firm to his wife just before being sanctioned by the EU. “EuroChem Group AG is not sanctioned, has never been sanctioned, and is free to ...
Updated red flag indicators of potential export control and/or sanctions evasion, Best practices for industry to address these red flags, and Screening tools and resources to assist with due diligence. The guidance is to help prevent the diversion of controlled items to Russia, including through th...
CDD and KYC are key foundations to sanctions compliance. If firms fail to obtain the right information as part of these processes, sanctions screening will be ineffective. For example, if firms do not collect appropriate beneficial ownership information for CDD, there is a risk that a client t...