sanctions risk should be assessed across the supply route, bank, goods and participants together
Sanctions-sensitive transaction: supply route, bank and counterparty
The bank, logistics providers and counterparty each review the transaction. In a sanctions-sensitive shipment, check the supply route, parties, payment, goods and documentary explanation separately.
Where the position usually weakens
A position weakens when the document, deadline and evidence do not fit together. Start with the facts, response period and evidence chain.
What to check now
Start with the documents that explain the facts, deadline, money, goods and parties' actions rather than collecting the entire archive.
a bank does not repair a weak transaction structure; it may be the first participant to expose the weakness
a sanctions-sensitive transaction should not be treated as ordinary route geography
Materials on this issue