Sanction law Practice

• (audit of sanctions compliance in export-import transactions), development and implementation of policies, processes and procedures to ensure compliance with sanctions requirements and international trade rules;
• verification of the project or the intended counterparty (i.e., whether joining the project or starting a relationship with a particular person can lead to sanctions);
  
• identification of sanctioned persons: individuals and legal entities are directly listed in the relevant lists, however, according to the sanction legislation of the EU and the United States, companies that directly or indirectly belong to one or more persons from the sanctions list are also subject to restrictions (i.e., a full check of the company's corporate structure including its ultimate beneficiaries);
• checking the corporate and contract structures of the company for compliance with the sanctions legislation of the country of business;
• drawing up individual regulations for compliance with US sanctions legislation (for a legal entity whose shareholders or beneficiaries are US Person, or if the company does business in the USA);
• advising western partners on obtaining official permits from the relevant EU / US competent authorities, such as the EU Council, OFAC, etc. in relation to work in Russia, as well as obtaining permits to work with persons under sanction;
• sanctions risk assessment services for foreign imports and Russian exports, as well as conducting business in sanctioned territories.

• monitoring compliance with international trade rules and sanctions risks: OFAC, EU sanctions / embargo management (control of checks for affiliation with a blocked legal entity) OFAC>> 50% rule, CAATSA, end-user / user control, KYC & Due Diligence for Russia , Eurasia, the Middle East, Western and Eastern Europe;
• control of world trade rules: international arms trade rules (ITAR), export control rules (EAR), including anti-boycott rules, customs rules, an agreed tariff plan (HTS) and foreign trade rules (FTR).

Individualized screening of foreign company in the country targeted by sanctions, drawing up a business portrait of Russian company and (or) beneficiary to assess, hedge and eliminate sanctions risks:

• verification of the company in screening risk management systems, databases (such as World-Check - Refinitiv from Thomson Reuters, DOW Jones, D&B, WorldCompliance from LexisNexis, RDC from Regulatory Data Center, etc.);
• collection and analysis of information on the PEP status of a resident of the Russian Federation (Politically Exposed Person, politically significant person) - the assignment of this status by the compliance of Western banks and financial institutions is negative for the client, his business, family members and partners;
  
• legal advice on possible risks and consequences arising from the assignment of PEP, PEP-S and other statuses to the client, members of his family;
  
• adjustment of customer information in the above databases to relevant information;
  
• preparation of memoranda (written and analytical reports) on the reasons and grounds for the sanctioned “toxicity” identified by customers and other related risks arising from Western banks serving them in connection with customer relationships.