Complying with the increasingly complex sanctions landscape is demanding firms expand their management of risks beyond annual, list-based assessments of potential entanglements with known sanctioned entities and the companies they own.
More and more, thanks to pressure from regulators and Western governments, companies must understand not just whether they are directly doing business with a sanctioned individual or company—they also must recognize the ever-changing tricks and sleight of hand used by sanctioned entities to access Western markets by adjusting their internal controls accordingly.
