44 · White collar defence and regulation · UE · OFAC
Economic sanctions
What assistance changes in this practice, what it does not change, and the time reduction actually observed.
Where the gain is real
Screening of counterparties and flows, reconstruction of ownership chains, monitoring of the lists and applicable regimes.
Where it is slight or nil
Licence applications, meetings with the authority, the decision to exit a market.
Observed time
−61% at constant case scope, on cases closed over the last three financial years. This measure says nothing about the quality of the outcome.
What the practice covers
- Screening of counterparties, beneficial owners and flows
- Reconstruction of ownership chains against the control rules
- Monitoring of the lists, sector regimes and extraterritorial measures
- Review of contracts and of sanctions clauses, portfolio by portfolio
- Export controls, dual-use goods and the licences required
- Retrospective audit of transactions and preparation of disclosures