Sanctions Compliance: understanding indirect ownership and control

2022 0515 Moddy 02To comply with sanctions rules, corporations must consider ownership and control of their customers and business partners – including indirect ownership and control, which can be difficult to determine.

Doing business with a directly sanctioned entity poses risks, but entities can also be “indirectly” sanctioned, or sanctioned “by extension”, owing to their ownership or control. Identifying such entities can be complicated and time-consuming without the proper systems and data.

A robust sanctions compliance program should include ownership and control requirements that consider:


  • How indirect ownership and control affects supply chains
  • Ownership percentages in the aggregate
  • Director and ownership control


DOWNLOAD this paper to learn how your organization can better protect itself from sanctions risk.



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