Sanctions: are you confident you can see the whole picture?

It's a challenge complying with tightening sanctions regulations, and the complexity of corporate ownership structures just adds to the challenge. As well as identifying sanctioned companies, you need to be aware of the entities they're linked to.

In this diagram, Company A is on a sanction list. So subsidiaries B, C, D and E will also be sanctioned, because Company A directly, or indirectly, owns more than 50% of each of them.

Can your processes show you this level of detail?

The challenge in practice

Recently we reviewed 20 individuals and entities that were added to the USA's Office of Foreign Assets Control (OFAC) list on a particular day. Using our comprehensive ownership structures, we discovered that they actually control over 1,000 subsidiary entities, and these are 'sanctioned by extension'.

Compliance stress testing

To help you make sure that you're compliant with the OFAC and EU Sanctions regimes, here are some key compliance questions you might want to ask yourself:

• Are you confident that you're screening against official entity names – using informal company names won't return the same results?
• Can you identify if a sanctioned entity can issue public debt?
• Assets can be transferred between entities quickly and your systems need to be agile. How quickly can you identify all the entities that are controlled directly or indirectly by sanctioned individuals or entities?
• What systems do you have in place so you can monitor ownership changes to see how they impact on the status of individuals and entities who have previously been 'cleared' by your checking processes?
• Can you identify entities that are sanctioned by extension?

We can help you automate this time-consuming process

In one month we analysed towards the end of last year 7 million companies had changes in their ownership structures. Our combination of information and powerful software not only shows you companies 'under the radar' but is also incredibly fast – saving you huge amounts of time and providing more accurate screening.

Our Orbis database has information on:

• Nearly 243 million companies globally 
• Around 80 million ownership links, with 100,000 more added every week

We have the solution that helps you automate, centralise and monitor your compliance research.

Your free trial

Register for your free trial of our solutions for compliance professionals. Call us on +44 (0)20 7549 5000 or drop us an email.

White paper

You might also be interested in our white paper, The definitive guide to beneficial ownership, which touches on this subject.