A sanctions and third-party review.
- 011,400Counterparties screened
- 024.2mRecords reviewed
- 037 monthsReview period
- 04OFSIUK regulator
Our team was appointed by the board’s special committee to review the group’s exposure to sanctioned counterparties across its chartering and freight-forwarding network—an investigation turning on beneficial ownership, vessel movements and the adequacy of existing screening controls.
The question
Media reports suggested that cargoes handled by the group may have reached sanctioned end users through intermediaries. The board needed an independent view of whether breaches had occurred, how far the exposure extended, and whether any matter required voluntary disclosure to the regulator.
Our approach
We screened fourteen hundred counterparties against sanctions and ownership data, then matched shipping records against satellite vessel-tracking to flag unexplained route deviations and transfers at sea. Flagged transactions were traced through payments and correspondence, with each conclusion graded by the strength of its supporting evidence.
The findings
Most exposure proved to be screening gaps rather than breaches. A small cluster of shipments, handled by a single regional agent, showed indicators of ownership concealment and was escalated promptly. Controls over onboarding and agent oversight fell short of the group’s own policies.
The outcome
The board made a voluntary disclosure on the escalated shipments and terminated the regional agency relationship. The regulator closed its enquiry without a penalty, citing the quality of the disclosure, and our recommendations have since been embedded in the group’s compliance programme.
In sanctions work, a well-evidenced voluntary disclosure is often the strongest defence available.