Sanctions compliance—considerations for corporate crime lawyers
Produced in partnership with Roger Matthews of Dentons and John Binns of BCL Solicitors LLP

The following Corporate Crime practice note produced in partnership with Roger Matthews of Dentons and John Binns of BCL Solicitors LLP provides comprehensive and up to date legal information covering:

  • Sanctions compliance—considerations for corporate crime lawyers
  • Sanctions compliance policy
  • Key steps in ensuring compliance
  • Practical steps

Sanctions compliance—considerations for corporate crime lawyers

Organisations should have a clear understanding of both the financial and trade sanctions (where appropriate to their business) and be able to identify risks raised by particular customers, services, products and transactions in high-risk jurisdictions. This Practice Note summarises key issues corporate crime lawyers should consider when advising organisations on sanctions compliance including screening and checking of staff, agents and counterparties and due diligence. It also provides links to useful sanctions compliance Precedents.

Sanctions compliance policy

It is good practice for organisations to have in place a sanctions compliance policy affirming the business’ commitment to sanctions compliance and setting out the procedures which staff are to follow to ensure compliance (these procedures will need to be tailored to the size and type of organisation, the jurisdictions it is based in, the jurisdictions it does business with, the sectors it operates in, and the nature of its business). It is not realistic to expect all staff in a company to be familiar with the details of all applicable sanctions laws, so having such a policy will help by establishing procedures which staff can follow, but which are designed to ensure that risks are detected or alerted to relevant legal or compliance functions. See further Precedents:

  1. Financial sanctions policy

  2. Trade sanctions policy

Formulation of a sanctions policy should start with a risk assessment, see

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