A comprehensive guide to client screening and sanctions compliance for international trade operations.
International sanctions are legal measures that restrict trade with certain countries, entities, and individuals. Non-compliance can result in severe penalties, reputational damage, and criminal liability. This procedure ensures thorough due diligence for all business relationships.
For new or existing clients, always inquire how they found us (website, recommendations, public information).
Determine what goods are of interest and initially check the Integrated Tariff Management System (ITVS) to ensure that the specific goods are allowed for import and export, and whether other restrictions or Customs/government requirements apply.
Check ITVSRequest the client company's registration data showing all officials and owners. Cross-reference with public Russian company databases. If information differs, always request an explanation from the client. If explanations are imprecise, incomplete, or false, or if the client's founders consist of multiple company chains, inform the client that cooperation is not possible.
Russian Company DatabaseScreen all individuals against multiple sanctions lists. If a person is found on any sanctions list, immediately inform the client that cooperation is not possible. Additionally, use public media, social networks, or search engines to gather supplementary information for decision-making.
For raw materials (flavorings, fabrics, ribbons), always determine the purpose, final product, manufacturer, end consumer, and target market. If any connection to sanctions lists or overly complex intermediary chains is found, inform the client that cooperation is not possible.
Include written contract provisions for withdrawal if sanctions come into legal force.
Print or otherwise record all suspicious, direct, or indirect flagged information.
Strictly follow bank requirements and recommendations. Verify from which Russian bank payments will be made and whether the client's bank is on sanctions lists.
Conduct weekly screening of existing clients, plus immediate re-screening after each new sanctions package is published.
Before sending goods, coordinate the shipment with VID Customs (rvd.iaun@vid.gov.lv) and the Strategic Goods Export Control Division (snpekn@mfa.gov.lv) if required by ITVS regulations.
Additionally, check Russian government procurement databases and use public media, social networks, or Google for supplementary information.
VID Customs
rvd.iaun@vid.gov.lvStrategic Goods Export Control
snpekn@mfa.gov.lvSanctions compliance is complex. Our experts can help you navigate international trade regulations.
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