Sanctions compliance that holds up under pressure.
The EU, UN, US and UK expand their sanctions regimes at ever shorter intervals – and pursue circumvention through third countries, vessels and ownership chains. We set up screening, processes and evidence that work day to day and stand up to audit.
When to bring us in
- A new sanctions package has to be implemented within days – lists, goods bans, wind-down periods.
- Screening produces too many alerts, and real risk gets lost in the noise.
- Business routed via third countries raises circumvention questions – Central Asia, the Caucasus, Türkiye or the UAE.
- The ownership and control of counterparties are unclear.
- Internal audit, external auditors or the supervisor have raised findings.
- US or UK touchpoints – dollar payments, US-origin goods, UK subsidiaries – raise extraterritorial questions.
What we do for you
- 01
Sanctions risk assessment
A structured assessment of business model, products, countries, customers and payment routes – the basis for every control that follows.
- 02
Screening design and calibration
Lists, data fields, matching logic, thresholds and alert handling for names, vessels, ports and goods – documented and tested.
- 03
Ownership and control
A method for ownership chains and control tests under EU guidance and the OFAC 50% rule, with clear escalation paths.
- 04
Circumvention risk
Red flags for third-country routing, transshipment, the shadow fleet and Common High Priority List goods; embedding the “no Russia” clause (Art. 12g) and the best-efforts obligation (Art. 8a Regulation (EU) 833/2014) in your process.
- 05
Policies and alert handling
Sanctions policy, procedures, four-eyes approvals, asset freezing and reporting lines to the competent authorities.
- 06
Training
Role-based training for front office, trade operations, compliance and management – built on real cases.
Deliverables that last
- Documented sanctions risk assessment
- Screening design with calibration and test evidence
- Updated policy and procedures
- Red-flag catalogue for your products and corridors
- Action plan with owners and deadlines
- Training materials and attendance records
Our tools for this
One access point for country risk, regulatory change and reviews – the results of our advice keep running here day to day.
Sanctions regimes with a country nexus (UN, EU, US, UK), the EU anti-circumvention tool and export-control country groups – every classification with its source and date.
Screens every party, beneficial owner and vessel of a transaction; confirmed sanctions hits hold release and payout.
New designations, packages and enforcement actions every morning – from primary sources only.
- Regulations (EU) 833/2014 and 269/2014 (Russia), (EU) 765/2006 (Belarus), (EU) 267/2012 (Iran)
- EU Best Practices for the effective implementation of restrictive measures (July 2024 update)
- Directive (EU) 2024/1226 on the criminalisation of sanctions violations
- UN Security Council sanctions
- US: OFAC programmes, 50% rule, secondary sanctions exposure
- UK: OFSI (financial sanctions) and OTSI (trade sanctions)
- Germany: Foreign Trade and Payments Act (AWG) and Ordinance (AWV)
Frequently asked questions
Do you also provide the legal assessment of individual transactions?
We structure the facts, assess the risk and prepare the decision. The binding legal assessment – for instance whether an exemption applies or a licence is needed – sits with your legal department or external counsel. We are happy to work with them directly.
Which sanctions regimes do you cover?
Our focus is EU and UN sanctions and, given their practical reach, the US (OFAC) and UK regimes. Russia and Belarus, Iran and North Korea are the main country programmes, alongside thematic regimes such as terrorism, human rights and cyber.
How quickly can you help when a new package lands?
We track new packages daily. Within an ongoing engagement we deliver a rapid impact assessment: which products, customers, goods and deadlines are affected, and what needs to happen by when.
Other practice areas
Sanctions compliance: let’s talk about your case.
In a demo we show you TFI TradeCore on your products, countries and use cases – and discuss where advisory or an audit gives you the most leverage. No obligation, confidential, and with specialists in trade finance.
or write to info@tradefinance-intelligence.com