Sanctions

What are factors that increase sanctions risk?

We recommend taking into account the following factors which increase sanctions risk:

  1. their economic activity is related to a territory or border area of a territory or state that is subject to sanctions;
  2. their economic activity is related to the military industry; the sale, manufacture, import or export  of dual-use goods subject to sectoral sanctions; or specialised foreign agencies (military design bureaux, space technology research agencies, etc.);
  3. their economic or personal activities do not match their declared economic or personal activities, or information on the business partner does not conform to their economic or personal activities;
  4. business relationships with companies which have the characteristics of a legitimate business which are used to conceal their financial malpractice, including beneficial owners or economic activities (front company), or business relations with inactive companies for a longer time period and whose shareholders, directors or other authorised persons are also inactive companies (shell companies);
  5. payments are made on behalf of your business partner by a third party who is a resident of a territory or country which is subject to sanctions; 
  6. cooperation with a service provider transporting goods in states and territories subject to sectoral sanctions or in the border zone of such territories or states;
  7. cooperation with a service provider which publicly available information indicates is a provider of transport services to companies operating in a territory or state subject to sanctions;
  8. the carriage of goods involved in your transactions takes place in a territory or state, or in the border zone of the territories or states subject to sectoral sanctions, using vehicles whose routes cannot be traced precisely using publicly available internet resources;
  9. the price of the goods or services involved in the transactions differs significantly from the average market price, or the type of transport or storage of the goods involved in the transaction, the route, packaging or other characteristics do not correspond to general sectoral practice;
  10. the same documents are used to justify several unrelated transactions;
  11. the documents supporting transactions contain indications of fraud, which could indicate potential sanctions evasion;
  12. within the framework of non-cash remittance, funds are transferred or received from states or territories associated with the export of prohibited goods and services subject to sanctions or carried out in the vicinity of such states or territories.
     

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