BERNEV / CUSTOMS LAW
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Sanctions restrictions and transaction risk

Sanctions risk should be assessed across the transaction: goods, counterparty, bank, supply route and documentary explanation. A weakness in one part can affect the others.

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.

01only the goods or only the counterparty are checked, rather than the full chainfor pre-transaction screening, review the goods, counterparty, supply route and bank before payment or the supply structure is fixed
02the bank, logistics provider and customs may identify different risk indicators in the same transactionrisk should be assessed before payment and before the supply structure is fixed
03the documents do not explain the supply route or commercial logic of the transaction in a sanctions-sensitive environmenta sanctions problem can develop into a more expensive supply dispute

What to check now

Start with the documents that explain the facts, deadline, money, goods and parties' actions rather than collecting the entire archive.

01

Identify the specific restriction cited by the bank, counterparty or other participant.

02

Check which person, goods, payment or transaction the restriction is said to affect.

03

Compare the stated basis with an available official source and transaction documents.