Sectors / Cross-border trade & sanctions
Sector vi.

Cross-border trade
& sanctions.

Designations move quickly and ownership is easily obscured. We test counterparty, destination and route.

What we test
Counterparty ownership
Destination and end use
Sanctions across the transaction
§ A — Standards

Standards & regulation.

The frameworks we work to in this sector.

SAMLA
2018 · UK

UK autonomous sanctions framework.

OFSI guidance
Current

Licensing, ownership and control.

OFSI enforcement
PACA 2017 s.146

Civil penalties for sanctions breaches.

OFAC
31 CFR Ch. V

SDN list and the 50% rule.

IEEPA
50 USC 1701

Statutory basis for US sanctions.

EU 833/2014
As amended

EU Russia restrictive measures.

Money Laundering Regs
2017 · Regs 18–35

CDD, EDD and PEPs.

FATF Recommendations
Recs 10 · 12 · 15 · 22

International CDD standard.

Bribery Act
2010 · s.7

Failure to prevent bribery.

ECCTA
2023 · Part 5

Failure to prevent fraud.

FCPA
15 USC 78dd-1

US anti-bribery.

ISO 37001
2016

Anti-bribery management.

ISO 28000
2022

Supply chain security.

AEO · CTPAT
HMRC · US CBP

Trusted trader programmes.

UK GDPR
DPA 2018

Data protection in diligence.

§ B — Screening

What we screen against.

Every counterparty, owner and director.

UK Sanctions List
OFSI · HMT

UK financial sanctions.

UN Consolidated
United Nations

UN Security Council list.

OFAC SDN
United States

Specially Designated Nationals.

EU Sanctions
European Union

EU consolidated list.

BIS Entity List
United States

Export-restricted parties.

BIS Denied · Unverified
United States

Denied and unverified parties.

DDTC Debarred
United States

ITAR debarred parties.

World Bank Debarred
Global

Debarred firms and individuals.

Companies House
United Kingdom

Registry, officers and PSC.

PEP registers
Domestic · Foreign

Politically exposed persons.

Adverse media
Global

Reputational and legal exposure.

Next step

We keep things moving.

A bid, an audit, a counterparty or a contract. Send it over, and we will come back with scope, fee and timeline within 24 hours.

Send a brief →— Reply within 24h
Container port elevation A densely detailed front-elevation line drawing of a container port in brass on deep navy. A large container ship with a raked bow, hull plating, draft marks and an accommodation block carries eleven bays of stacked containers. Two ship-to-shore gantry cranes stand on the quay: one with its latticed boom lowered over the ship, a trolley and a container suspended on the spreader, the other with its boom raised. To the right a rail-mounted gantry spans stacked yard containers. Water is drawn as layered wave lines with reflections; the quay carries crane rails, bollards, fenders and mooring lines.
Container terminal · Elevation