Several regimes, one transaction
Sanctions compliance for a business that crosses borders is rarely about one government's list. The United States, the European Union, the United Kingdom, Korea, and the United Nations each maintain their own measures, and their lists and country restrictions differ in scope and timing. A deal that is permitted for a Korean parent may be prohibited for its U.S. subsidiary, and a few jurisdictions go further and restrict companies from complying with certain foreign sanctions. Where the rules pull in different directions, the answer usually depends on which entity is acting, which people are involved, and how the money moves, so it helps to settle in advance which entity is responsible for each step.
People and contracts are where it breaks
A frequent gap involves employees who are U.S. persons working for a non-U.S. company, since they may be barred from approving or facilitating a transaction their employer is free to do; recusal procedures help, but they have to be real and documented. Another gap sits in contracts. When new sanctions take effect mid-performance, the question becomes whether the agreement allows suspension or termination and what happens to payments already in transit. Review your standard terms for sanctions representations, compliance-with-law clauses, and termination rights before a crisis tests them. Keep internal emails about sensitive counterparties factual, because a regulator may read them one day.
Setting priorities with you
We usually start by mapping your entities, the nationalities and locations of key decision-makers, your banks, and your largest counterparties, and then identify where sanctions exposure concentrates. From there we discuss whether your current screening and approval steps match that exposure, and where policies written for one country are being applied to another without adjustment. If a transaction is pending and uncertain, we can look at it on its own facts. If something may already have gone wrong, we talk through stopping the activity, preserving records, and whether a disclosure to one or more authorities should be considered, keeping in mind that different regulators may expect different things.
