Sanctions and Compliance

A company with no connection to a sanctioning state may still be affected by its measures, through the currency in which it settles, the banks in its payment chain, or the ownership of its counterparty. Exposure is more often discovered through a refused payment than through a regulatory notice.

Digests Global Law Firm advises companies, financial institutions and individuals on the effect of international sanctions and export controls on operations connected with Uzbekistan, and on compliance with anti-corruption and anti-money-laundering requirements.

Our sanctions and compliance practice covers:

• Exposure assessment. Analysis of contracts, counterparties and proposed transactions against applicable sanctions regimes, export control restrictions and anti-corruption requirements.
• Counterparty screening. Verification of ownership and control, including indirect holdings by designated persons.
• Transaction advice. Sanctions analysis in acquisitions, lending and project finance, including due diligence, contractual protections and conditions.
• Payment and settlement. Advice on payment routing, correspondent banking, and the reasons a payment is delayed or refused.
• Compliance programmes. Preparation and implementation of internal policies on sanctions, anti-corruption and anti-money-laundering, including procedures required by Uzbek legislation on countering the legalisation of criminal proceeds.
• Training. Instruction of personnel responsible for applying those procedures.
• Investigations. Internal investigations, and representation in dealings with regulatory and law enforcement authorities.
• Monitoring. Tracking of changes in the applicable regimes and assessment of their effect on existing arrangements.

Sanctions regimes change frequently and are not always consistent with one another. We advise on the position as it stands at the time of advice and identify where obligations conflict.