Practice 01
Sanctions Risk & Compliance
When exposure is uncertain, the first job is to see it clearly. We design and test sanctions compliance — screening, ownership and control analysis (including the OFAC 50% rule and the EU control test), due diligence and training — so that a held payment or a screening hit has a defensible answer ready.
Applicable regime & authority
Primary authorities: the U.S. Office of Foreign Assets Control (OFAC) and EU National Competent Authorities. The OFAC 50% Rule governs ownership aggregation; reporting and recordkeeping sit under 31 C.F.R. Part 501.
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
Licensing & 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 →Related practiceExport Controls & Dual-Use
Controlled goods, software and technology move only within the rules.
Read more →FAQ
Questions clients ask first.
What is the OFAC 50% rule, in practice?
An entity owned 50% or more, directly or indirectly, by one or more blocked persons is itself treated as blocked — even if it is not named on a list. Aggregating ownership across a chain is where most screening failures begin.
How is the EU control test different?
The EU looks beyond a 50% shareholding to whether a designated person controls an entity in fact — for example through board appointments or decisive influence. A counterparty can be clear under one test and caught under the other.
What does a screening programme actually need?
A defensible programme has a written risk assessment, list and adverse-media screening calibrated to that risk, an ownership-and-control procedure, escalation and recordkeeping, and periodic testing. The aim is a position you can show a regulator or a bank.
A payment was held — what is the first step?
Establish which regime and authority are in play, whether the counterparty is owned or controlled by a listed person, and whether a licence route exists. A written position turns a frozen payment into a decision rather than a guess.
Get a written position you can defend.
For compliance teams and general counsel. A short call, then a fixed-fee written position — response within two hours in business hours.