Sanctions & Export Controls
Find the Exposure
Before a Regulator Does.
A 4–8 week review across sanctions regimes and export controls that goes past name screening — into ownership structures, technology transfer, and the parts of your supply chain you never contracted with.
4–8 Weeks
Duration
OFAC · EU · UN · UK
Regimes
Exposure Map
Output
Scope of Review
Where the Exposure Actually Hides
Screening software clears the names on your list against the names on theirs. It does not trace ownership through three holding companies, classify the technology your engineers emailed to an overseas affiliate, or tell you who your distributor sold to last quarter. Those are the places exposure is usually found.
Regimes
Multi-Jurisdiction Regime Mapping
Which sanctions regimes bind you and why — OFAC through US nexus, the EU and UK regimes through establishment, currency, or nationality of personnel, and UN measures as implemented in each jurisdiction where you operate. Regimes rarely align, and the review identifies where their obligations diverge for your specific business.
Ownership
Ownership & Control Tracing
Tracing beneficial ownership through holding structures, nominee arrangements, and layered corporate vehicles to identify entities that are restricted by virtue of their owners rather than by listing — the aggregation principle commonly referred to as the 50 percent rule — together with the indicators of de facto control that sit outside any list.
Export Controls
Export Controls & Technology Transfer
Classification exposure under the EAR and, where relevant, the ITAR: dual-use items, controlled software and technology, deemed export risk within your own workforce, re-export and de minimis pathways through your distribution chain, and the technology your engineers share with overseas affiliates as a matter of routine.
Supply Chain
Supply Chain & Distributor Exposure
Where restricted parties sit two and three tiers away from your direct relationships — sub-suppliers, freight forwarders, resellers, and end users you never contracted with. Includes diversion-risk patterns in your distributor network and the contractual controls that would let you act on what you find.
Transactions
Sanctions Inheritance Risk
What you would be acquiring along with a target: historical dealings that create successor liability, restricted counterparties inside its book of business, unremediated conduct, and licensing dependencies that do not transfer cleanly. Sequenced to sit inside a live deal timetable where required.
This review is advisory work produced to be used by your legal team — it is not legal advice and does not replace counsel. Where the finding is a program problem rather than a discrete exposure, it hands off to compliance; where a government or supervisory body is the client, to financial crime and anticorruption.
The Deliverable
Findings You Can Act On
and Defend
Everything we deliver is built so that a compliance officer can execute against it and a general counsel can put it in front of a board or a regulator without rewriting it first.
Output 01
Exposure Map
A documented view of every point where your operations touch a restricted party, a controlled item, or a sanctioned jurisdiction — organized by entity, relationship, and regime, with the evidence behind each finding attached. Written to be handed directly to counsel or to a regulator.
Output 02
Prioritized Remediation Plan
Findings ranked by severity and by how quickly they can be closed. Each item states the exposure, the recommended remediation, the internal owner, and the sequence — so a compliance team with finite capacity knows what to do on Monday.
Output 03
Escalation Triggers
A defined set of conditions that should stop a transaction, freeze a relationship, or reach the general counsel immediately — written as thresholds someone can apply in the moment, and mapped to the people who hold the authority to act on each.
Output 04
Control Gap Assessment
Where your existing screening, onboarding, and classification controls would have failed to catch what the review found — with specific recommendations on process, data, and contractual language.
The Engagement
How the Review Is Run
Four to eight weeks depending on the number of entities, the complexity of the ownership structures, and whether export control classification is in scope. Work is conducted under confidentiality throughout and can be run at the direction of counsel where privilege considerations apply.
Scoping & Data Capture
Weeks 1–2
Nexus analysis to establish which regimes apply and why. Capture of counterparty registers, product and technology catalogs, distributor agreements, and existing screening output. We work from your actual records.
Screening & Tracing
Weeks 2–5
Structured screening across applicable lists, followed by ownership tracing through corporate registries, control analysis, adverse media review, and classification assessment of controlled items and technology.
Findings & Prioritization
Weeks 5–7
Every hit is adjudicated. False positives are cleared and documented; genuine exposures are assessed for severity, and the remediation plan is sequenced against your capacity to execute it.
Delivery & Handover
Weeks 7–8
Working session with legal and compliance, then delivery of the exposure map, remediation plan, escalation triggers, and control gap assessment. Where the findings need to go to counsel or to a board committee, we help you frame them.
Related
Adjacent Work
Transaction Diligence
Deal-timedWhere the exposure question sits inside a live acquisition and has to be answered on the deal calendar.
Monitoring & Early Warning
RetainerStanding coverage of designation activity and regime change affecting the counterparties this review identifies.
Country & Market Entry Risk
3–6 weeksThe wider jurisdictional picture when sanctions exposure is one part of a market entry decision.
Get Started
What prompted the question?
A new designation, a pending transaction, a distributor you are no longer sure about, or a board asking whether anyone has checked. Tell us which, and we will scope the review around it.
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