Key takeaways:
Sanctions compliance is a system of internal controls aimed at mitigating sanctions risks. Though, as a rule, sanctions compliance involves a whole system including a compliance manager, policies, instructions and audits, these instruments can be used separately. They demonstrate their efficiency in mitigating sanctions risks.
The main risks that can be mitigated by sanctions compliance instruments are (1) the company or its managers falling under blocking sanctions, (2) difficulties in dealing with counterparties from third also “friendly” countries, (3) payments and other financial assets being blocked.