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Expertise

Sanctions & export control compliance

Screening, licensing and internal controls under EU, UK and US regimes.

What this covers
  • Counterparty screening programme
  • Screening on EU, UK and US lists
  • Licence and derogation applications
  • Sanctions clauses in contracts
  • Internal controls and staff training
  • Exposure review and remediation plan

We advise companies with Ukrainian exposure on the sanctions regimes that actually apply to them — EU, UK and US — and on how those regimes differ from one another in practice.

A screening list that works in one jurisdiction will not work in another. We build the process around your counterparties, your sector and the way your contracts are actually signed, then document it in a form that survives an audit.

Where a licence, a derogation or a structured carve-out is available, we identify it early. Where it is not, we tell you plainly rather than leaving you to discover it at the payment stage.

The service of sanctions compliance monitoring and KYC (Know Your Customer) partner verification involves ensuring that business partners and clients adhere to relevant sanctions regulations and verifying their identity and legitimacy. This service includes several key components:

- Screening: Regularly check business partners and clients against global sanctions lists to ensure they do not engage with sanctioned entities.

- Alerts: Setting up automated alerts for any changes or updates in sanctions lists that might affect current partnerships.

- Reporting: Generating detailed reports on compliance status for internal review and external audits.

2. KYC (Know Your Customer) Verification:

- Identity Verification: Collecting and verifying identity documents of partners and clients to confirm their legitimacy.

- Risk Assessment: Evaluating the risk profile of partners and clients based on various factors such as their business activities, geographic location, and financial status.

- Ongoing Monitoring: Continuously monitoring the partners and clients for any changes in their status or behaviour that might indicate increased risk or non-compliance with regulations.

This service ensures that companies can confidently engage in business relationships, knowing that their partners are compliant with international sanctions and that they have a verified and legitimate background.

- International Law: Advising on compliance with international humanitarian law, arms control treaties, and defence agreements.

- *Regulatory Insight:* Navigating the complex regulatory landscape to ensure lawful and ethical agreements.

FAQ

Frequently asked

Which sanctions regimes apply to a Dutch company with Ukrainian exposure?

In practice three regimes matter: EU, UK and US. They overlap but do not mirror one another, and a list that works in one jurisdiction will not work in another. We identify which of them actually reach your counterparties and your transactions before advising on any control.

What does a screening programme actually consist of?

A list to screen against, a defined escalation path when a hit occurs, and a documented owner for each step. The part most programmes miss is the escalation path: a hit with nobody responsible for deciding what happens next is not a control, it is a report.

Can a licence or derogation be obtained after the transaction has started?

Sometimes, but the window is narrow and the material often has to be submitted before the payment or the shipment, not after. We look for the available route early, and where there is none we say so plainly rather than leaving it to be discovered at the payment stage.

Contact

Tell us what
you are facing.

Tell us what you are facing. Send a short description and a named lawyer will come back to you within one business day.

+31687790693 office@keylegalfactors.com WTC, Gustav Mahlerlaan 10, 1023 VE Amsterdam, Netherlands

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