Sanctions due diligence: understand and manage rising complexity

An intricate landscape of sanctions regimes along with increasingly sophisticated techniques of circumvention mean that due diligence can no longer follow a single template. Dmitry Sachkov explores scenarios.

Dmitry Sachkov (dsachkov@stoneturn.com) is managing director of StoneTurn, a global professional services firm that works with law firms, corporations, and government agencies providing expertise in investigations, compliance, economics, technology, cybersecurity, along with business and litigation advisory.

Sanctions due diligence has long evolved from checking names against lists to conducting investigative research to reveal an often-hidden sanctions nexus. Two main drivers of this change are the growing complexity of US, EU and UK sanctions regimes, in addition to the increasingly sophisticated techniques of sanctions evasion and circumvention. Recent regulatory actions, especially in the United States, demonstrate that the landscape is intricate and non-compliance can be costly. As a result, sanctions due diligence can no longer follow a single template and should be tailored to specific risks and applicable regulatory requirements.