What the assessment looks at
A sanctions risk assessment examines where a business's activities could meet sanctioned countries, regions, or parties, directly or through intermediaries. It usually covers customers and their owners, suppliers, distributors and agents, banks and payment routes, the products or services involved, and the places where the company sells or sources. OFAC has described risk assessment as a central part of an effective compliance program and expects it to be revisited as the business changes, rather than treated as a one-time report. An acquisition, a new product line, or a new distributor in a higher-risk region is a typical point to update it.
Tracing ownership and intermediaries
Names on a list are the easy part. Much of the real work is tracing ownership, because entities owned by blocked persons at or above OFAC's threshold are treated as blocked, that ownership can be split or hidden behind holding companies, and signs of continuing control below the threshold also deserve a look. Intermediaries create their own risk: a distributor in a neighboring country may resell into a sanctioned market, and unusual freight routes or payment requests can be warning signs. Gather corporate registry records, beneficial ownership statements, and distributor agreements. Keep a record of how each conclusion was reached, because the reasoning matters if a decision is questioned later.
Turning findings into decisions
An assessment earns its keep when it leads to choices. After reviewing your operations, we discuss which relationships need enhanced due diligence, where contract terms should be tightened, which transactions may need a license, and whether any past activity deserves a closer look. We also consider other regimes that may apply to you, such as EU, UK, or Korean measures, and U.S. export controls where products or technology are involved. The result should be short enough to be read and specific enough that staff know what to escalate. If the assessment uncovers a possible past violation, we talk through the disclosure question before any outside report is made.
