Practice 06
Cross-Border Transactions & Sanctions Diligence
A sanctions question can stall or unwind a deal. We provide sanctions due diligence for M&A, trade finance and payments, and we design structured wind-downs — so the transaction proceeds on a defensible footing.
Applicable regime & authority
Primary authorities: OFAC, OFSI and EU measures, including Regulation (EU) 833/2014 where relevant. Diligence turns on ownership and control, the regimes in play and the timing of the steps.
Analysis
Full analysis is in preparation as part of the matrix build (Phase 2). This hub sets out the regime, the practical route and the FAQ; the detailed sub-topics — by authority, service and sector — link from here as they are published.
Practical steps
A decision-tree walkthrough of what to do, in order, will sit here. In the meantime, the FAQ below answers the questions clients ask first, and the Exposure Check gives a fast orientation.
Risk flags
Watch for secondary-sanctions reach, extraterritoriality across regimes, and fixed regulatory clocks. Where they apply, the time to act is measured in days, not weeks.
When to seek counsel
When a payment is held, a counterparty is newly designated, a deadline is running, or a position has to be defensible to a bank or regulator — a written assessment is the proportionate first step.
Cost & timeline framing
Most matters here start with a fixed-fee written position; larger engagements are scoped with a clear estimate. We do not charge success fees. See how we price.
Related practices
Sanctions Risk & Compliance
When exposure is uncertain, the first job is to see it clearly.
Read more →Related practiceLicensing & Authorizations
Some activity is permitted only with a licence.
Read more →Related practiceDelisting & Designation Challenges
A designation is not always the end of the matter.
Read more →FAQ
Questions clients ask first.
What does sanctions due diligence cover in a deal?
Ownership and control of the target and its counterparties, the regimes that touch the business, licensing needs, and the sanctions representations and conditions in the documents. The aim is a clear go / no-go with the risks priced in.
What is a structured wind-down?
An orderly exit from a relationship or market that has become restricted, sequenced and documented so that each step is permitted. Done early it protects value; done late it can become an enforcement issue.
Can a deal close while a sanctions issue is open?
Sometimes, with the right conditions, licences or carve-outs. The question is whether each step is lawful when it happens, which is what the diligence is for.
Who carries sanctions risk after closing?
That is set by the representations, warranties and indemnities, and by the conditions to closing. Getting those right is cheaper than litigating them later.
Get a written position you can defend.
For buyers, lenders, and parties to cross-border transactions. A short call, then a fixed-fee written position — response within two hours in business hours.