Sanctions

are legal restrictions imposed against certain persons, entities, sectors, vessels, goods, services or countries. are separate from money laundering and may apply even where there is no suspicion of criminal property.

risks frequently arise through ownership and control structures, cross-border transactions, trade activities and payments involving third parties. A client, counterparty, beneficial owner, asset or transaction may be prohibited or restricted because it is subject to financial, trade or transport sanctions. Breaching sanctions can expose individuals and the Firm to serious regulatory, civil and criminal consequences.

Lawyers must remain alert to sanctions risks and must never assume that the absence of money laundering concerns means a transaction is permissible. This means:

• understanding who owns and controls the client;
• understanding who benefits from a transaction;
• understanding where funds and assets are coming from and going;
• remaining alert to attempts to conceal ownership or connections; and
• escalating actual or suspected sanctions concerns immediately.