Sanctions Compliance Checklist

March 17, 2022

In late February 2022, the European Union, United Kingdom, and United States issued the first wave of sanctions against Russian banks and members of the Russian legislature. Australia, Canada among other countries have issued similar sanctions with additional restrictions and bans announced daily.

Why sanctions matter

Sanctions limit where and with whom regulated entities can do business. Sanctions can be assigned directly or by extension as defined by the OFAC 50% and EU ‘control’ regulations.

The scale of the restrictions against Russia may present compliance challenges. Moody’s Analytics can help you assess and mitigate your exposure to sanctions. Our checklist provides steps you can take to comply with new sanctions.

How to comply with sanctions

  1. Review master data, supplier and customer databases to verify you are not doing business with sanctioned entities.
  2. Identify all beneficial owners of your customers, counterparties and suppliers. Ensure analysis includes a review of complex or opaque ownership structures, including offshore holding companies, intermediary companies, and trusts.
  3. Enhance your due diligence. Screen and monitor transactions in real time using well-calibrated name-matching logic on relevant sanctions lists.
  4. Identify all commercial relationships with politically exposed persons.
  5. Identify high-risk locations, jurisdictions and industries for additional attention, rescreening and monitoring.

How Moody’s Analytics helps

Moody’s Analytics is the only provider combining timely sanctions data with ownership and control information. Updates to sanctions lists are processed and available to customers within one business day of publication. Moody’s Analytics GRID has seen a 22% increase in sanctions coverage since the start of the Russia/Ukraine military conflict.

Moody’s Analytics maintains the Orbis global company database of more than 425 million entities, including ownership, shareholder and control information. Our technology identifies individuals in the ownership hierarchy of your local entity so that you understand how sanctioned individuals and entities are connected through complex ownership structures. Doing so can uncover hidden risks in your customer and third-party networks. Firms are responsible for complying with sanctions by extension under the OFAC50% rule and the EU’s control rule.

Contact us today to review your sanctions screening process. If you need to assess your current risk exposure, we will work with you to complete a complimentary exposure check.  

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