Service · Sanctions
Sanctions compliance
Sanctions rules have no de-minimis: a single missed hit can trigger criminal liability and reputational damage. We make your sanctions compliance robust and workable.
What we do
- Sanctions risk assessment: which countries, clients, products and flows expose you to sanctions risk — including circumvention risk.
- Internal controls: governance and controls in line with the Dutch Regulation on Supervision under the Sanctions Act 1977, proportionate to your size.
- Screening design: tooling selection and calibration, fuzzy matching, alert handling and escalation — against EU, UN and national lists.
- Ownership & control: practical application of the 50% rule and unravelling complex structures.
- Freezing & reporting: clear protocols for freezing measures and reports to DNB or the AFM.
- Export & circumvention issues: the Russia sanctions package, anti-circumvention and supply-chain due diligence.