Client matter · Sanctions and delisting

Sanctions Delisting and Risk Reduction

Depositaries and brokers needed advice on sanctions-listing risk, individual delisting applications and preventive compliance measures.

The starting point

What happened

Some clients had already been listed, while others were assessing the risk of designation.
Individual applications for removal from the relevant list required preparation.
Business processes needed review for sanctions vulnerabilities.
Compliance measures were intended to reduce future exposure without implying a guaranteed outcome.

Supported preparation of an individual delisting application.

Developed and implemented sanctions-compliance procedures.

Reviewed business processes for potential sanctions exposure.

Initial assessmentDistinguished current restrictions from potential future risks.

ApplicationPrepared the legal basis for an individual delisting application.

Process reviewAssessed relevant business processes and sanctions vulnerabilities.

ImplementationDeveloped compliance and preventive measures proportionate to the identified risks.

Supported result

Clients received support with delisting work and an internal framework of measures intended to mitigate future sanctions risk.

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