Sectors / 06
Cross-border trade & sanctions
Designations move quickly and ownership is easily obscured. We test counterparty, destination and route.
Three questions, answered with evidence.
010203What we read.
- VesselIMO number, flag, ownership and AIS history.
- CargoProduct origin, including EU Regulation 833/2014 Article 3ma.
- PartiesOwner, manager and charterer, with the 50 per cent ownership rule applied.
Standards & regulation.
The frameworks we work to in this sector.
UK autonomous sanctions framework.
Licensing, ownership and control.
Civil penalties for sanctions breaches.
SDN list and the 50% rule.
Statutory basis for US sanctions.
EU Russia restrictive measures.
CDD, EDD and PEPs.
International CDD standard.
Failure to prevent bribery.
Failure to prevent fraud.
US anti-bribery.
Anti-bribery management.
Supply chain security.
Trusted trader programmes.
Data protection in diligence.
What we screen against.
Every counterparty, owner and director.
UK financial sanctions.
UN Security Council list.
Specially Designated Nationals.
EU consolidated list.
Export-restricted parties.
Denied and unverified parties.
ITAR debarred parties.
Debarred firms and individuals.
Registry, officers and PSC.
Politically exposed persons.
Reputational and legal exposure.
Related thinking.
Recent notes that bear on this sector.
Failure to prevent fraud, one year on. What “reasonable procedures” means for your third parties
Since 1 September 2025, large organisations are liable for fraud committed by employees, agents and subsidiaries for their benefit. The main defence is reasonable procedures, and third parties are where most organisations are thinnest.
The US “affiliates rule” is paused, not gone. Check who owns your customers.
Washington’s pause on the BIS affiliates rule was due to end on 9 November and is expected to follow the US–China truce to 10 January 2027. When it returns, companies 50% or more owned by listed parties face the same restrictions as their owners, whether or not they appear on any list.