Global Sanctions Insights at Your Fingertips 

Afghanistan is subject to international sanctions imposed by major regulatory bodies, including the United Nations (UN), the United States (US), the European Union (EU), and the United Kingdom (UK). These sanctions primarily target individuals and entities associated with the Taliban and other groups deemed to threaten Afghanistan's peace, stability, and security.

Numerous individuals and entities within Afghanistan are under targeted sanctions. The UN Security Council's 1988 Sanctions List includes individuals and entities associated with the Taliban. The US Office of Foreign Assets Control (OFAC) maintains a list of Specially Designated Nationals (SDNs) that includes Afghan individuals and entities linked to terrorism and narcotics trafficking. The EU and UK have similar lists targeting individuals and entities associated with the Taliban and other sanctioned groups.

Recommendations:

• Standard Due Diligence:
  • Verify the identities of all parties involved in transactions.
  • Assess the nature and purpose of business relationships.
  • Maintain accurate and up-to-date records of all transactions and communications.
• Enhanced Due Diligence:
  • Conduct thorough background checks on individuals and entities to identify any connections to sanctioned parties.
  • Scrutinize complex or unusually large transactions that lack apparent economic or lawful purpose.
  • Implement ongoing monitoring of business relationships to detect and report suspicious activities promptly.
• Screen Against Sanctions Lists:
  • Regularly consult and screen against the latest sanctions lists from the UN, US OFAC, EU, and UK to ensure compliance.
  • Utilize automated screening tools to identify potential matches with sanctioned individuals or entities.
  • Establish procedures for addressing potential matches, including escalation protocols and reporting mechanisms.
• Monitor for Regulatory Changes:
  • Stay informed about updates to international sanctions regimes related to Afghanistan.
  • Subscribe to official communications from relevant regulatory bodies to receive timely notifications of changes.
  • Adjust compliance programs and internal policies to reflect the latest regulatory requirements.

Risk Assessment: High Risk

Albania is not subject to comprehensive international sanctions by major regulatory bodies. However, certain individuals and entities within the country have been targeted by sanctions due to involvement in corruption and organized crime.

Notably, former Prime Minister Sali Berisha and his immediate family were sanctioned by the U.S. Department of State in May 2021 for significant corruption. In July 2022, the United Kingdom also imposed sanctions on Berisha, citing his alleged links to organized crime and corruption.

Recommendations:

• Standard Due Diligence:
  • Verify the identities of all parties involved in transactions.
  • Assess the nature and purpose of business relationships.
  • Maintain accurate and up-to-date records of all transactions and communications.
• Enhanced Due Diligence:
  • Conduct thorough background checks on individuals and entities to identify any connections to sanctioned parties.
  • Scrutinize complex or unusually large transactions that lack apparent economic or lawful purpose.
  • Implement ongoing monitoring of business relationships to detect and report suspicious activities promptly.
• Screen Against Sanctions Lists:
  • Regularly consult and screen against the latest sanctions lists from the U.S. Department of State, the U.K. government, and other relevant authorities to ensure compliance.
  • Utilize automated screening tools to identify potential matches with sanctioned individuals or entities.
  • Establish procedures for addressing potential matches, including escalation protocols and reporting mechanisms.
• Monitor for Regulatory Changes:
  • Stay informed about updates to international sanctions regimes related to Albania.
  • Subscribe to official communications from relevant regulatory bodies to receive timely notifications of changes.
  • Adjust compliance programs and internal policies to reflect the latest regulatory requirements.

Risk Assessment: Medium Risk

International Sanctions Status:
Algeria is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. However, there are some sectoral restrictions and arms embargoes imposed by certain countries.

Individuals/Entities under Targeted Sanctions:
There are no prominent individuals or entities within Algeria under targeted sanctions from international regulatory bodies like the UN, EU, or U.S. However, certain individuals or entities may be subject to restrictive measures imposed by individual countries for reasons unrelated to Algeria's general status.

Recommendations:

• Standard Due Diligence:
• • Verify the identities of business partners and customers based in Algeria.
  • Review ownership structures to ensure compliance with relevant local and international regulations.
  • Assess the source of funds and transactions to confirm they are not linked to sanctioned entities or individuals.
• Enhanced Due Diligence:
• • When engaging with high-risk sectors in Algeria (e.g., defense, energy), additional scrutiny should be applied.
  • Closely monitor any transactions involving politically exposed persons (PEPs) or individuals with connections to Algeria’s military or government sectors.
  • Investigate the ownership and control of entities involved in large or unusual transactions.
• Screen Against Sanctions Lists:
• • Screen all clients, transactions, and partners against global sanctions lists, including the UN, EU, U.S. Department of Treasury, and any national sanctions lists from jurisdictions you operate in.
• Monitor for Regulatory Changes:
• • Continuously track Algeria's status regarding international relations and any developments that might lead to changes in its sanctions status or result in new restrictions.
  • Monitor any shifts in the political landscape that may lead to changes in Algeria’s foreign policy or legal frameworks.

Risk Assessment:
Low Risk – Based on current sanctions information, Algeria poses a low risk in terms of international sanctions. However, sectors like defense and energy, or specific political entities, may require closer scrutiny due to their potential exposure to targeted measures.

Andorra is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. Although Andorra is not directly sanctioned, it must comply with international sanctions frameworks, particularly those set by the EU and the UN, as it aligns with EU regulations.

Individuals/Entities under Targeted Sanctions:

There are no prominent individuals or entities within Andorra under targeted sanctions from the UN, EU, or U.S. regulatory bodies. However, entities involved in financial services or other high-risk sectors may require closer monitoring, particularly those with connections to sanctioned countries or politically exposed persons.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Andorra.
  • Review ownership structures to ensure compliance with both local and international regulations.
  • Assess the source of funds and transactions to confirm they are not linked to sanctioned individuals or entities.
• Enhanced Due Diligence
  • For high-risk transactions or clients involved in sectors like finance, energy, or defense, apply additional scrutiny.
  • Closely monitor any transactions involving politically exposed persons (PEPs) or individuals with ties to Andorra’s financial sector.
  • Investigate the ownership and control structures of entities involved in large or unusual transactions.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, and U.S. Department of Treasury (OFAC).
  • Ensure compliance with any EU-specific sanctions regulations that may apply to Andorra.
• Monitor for Regulatory Changes
  • Stay updated on any changes in Andorra's alignment with EU sanctions and international regulatory frameworks.
  • Monitor shifts in Andorra’s financial regulations or political landscape that could lead to new compliance requirements or impact sanctions enforcement.

Risk Assessment:

Medium Risk – Although Andorra is not subject to direct sanctions, its financial sector and compliance obligations with the EU expose it to potential regulatory changes. Enhanced due diligence is recommended for transactions involving high-risk sectors or international exposure.

Angola is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. However, Angola is subject to certain sectoral sanctions and targeted measures related to individuals and entities involved in corruption, human rights violations, and other issues. The country has experienced international scrutiny over its governance, but sanctions are typically focused on specific sectors or persons rather than the entire country.

Individuals/Entities under Targeted Sanctions:

There are some individuals and entities within Angola that are under targeted sanctions, particularly from the United States, due to involvement in corruption, human rights abuses, and destabilizing activities. These sanctions are typically applied to specific individuals or entities in Angola’s political or business sectors, including those with ties to Angola's oil and diamond industries. The European Union and the United Nations may also impose sanctions on specific individuals or groups within Angola, particularly those involved in illicit activities.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Angola, especially in sectors such as oil, diamonds, and government contracts.
  • Review the ownership structures of companies operating in Angola to ensure compliance with international regulations.
  • Conduct background checks to ensure no ties to individuals or entities under sanctions, particularly in high-risk sectors.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients and transactions involving Angola’s government officials, PEPs, or individuals in sectors like natural resources or finance.
  • Scrutinize transactions involving politically sensitive or high-risk entities linked to Angola’s diamond, oil, or state-run sectors.
  • Investigate the ownership and control structures of entities involved in large, complex, or unusual transactions, particularly when dealing with parties from jurisdictions with close ties to Angola.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and any national sanctions lists in the jurisdictions you operate in.
  • Pay particular attention to individuals and entities that may be linked to corruption, human rights violations, or activities of concern within Angola’s natural resource sectors.
• Monitor for Regulatory Changes
  • Keep track of any changes in Angola’s political or economic environment that could lead to changes in its sanctions status.
  • Monitor shifts in Angola’s international relations or the adoption of new sanctions measures by the EU, UN, or the U.S.
  • Stay updated on changes in Angola’s financial regulations, particularly those aimed at combating corruption and enhancing financial transparency.

Risk Assessment:

High Risk – Angola presents a high risk due to its historical exposure to corruption, human rights concerns, and the involvement of certain individuals and entities in sectors under international scrutiny. Enhanced due diligence is recommended, particularly for transactions in sectors like oil, diamonds, and government contracts, which are more likely to involve individuals or entities under sanctions.

Antigua and Barbuda is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. While the country is not under widespread sanctions, it does adhere to international sanctions frameworks, including compliance with the EU and UN sanctions regimes, and has implemented measures to combat money laundering and financial crimes.

Individuals/Entities under Targeted Sanctions:

There are no prominent individuals or entities in Antigua and Barbuda currently under targeted sanctions by the UN, EU, or U.S. regulatory bodies. However, the country has been subject to scrutiny in the past regarding its financial services sector, particularly concerning offshore banking and its role in facilitating international financial transactions. Any individuals or entities linked to illicit activities, such as money laundering or corruption, may be subject to sanctions from other jurisdictions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers, especially those engaged in the financial services or offshore sectors.
  • Review ownership structures to ensure compliance with both local and international regulations.
  • Assess the source of funds and transactions to ensure they are not linked to sanctioned individuals or entities, particularly from high-risk jurisdictions.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients involved in the financial services industry, offshore banking, or politically exposed persons (PEPs).
  • Investigate large or complex transactions, particularly those involving high-risk countries or entities with a history of sanctions.
  • Scrutinize the ownership and control of entities in sectors where there could be risks related to money laundering or corruption.
• Screen Against Sanctions Lists
  • Regularly screen clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and any national sanctions lists.
  • Be particularly vigilant in monitoring entities or individuals involved in offshore banking and financial transactions that may have connections to sanctioned countries.
• Monitor for Regulatory Changes
  • Stay updated on any changes in Antigua and Barbuda’s financial regulations, particularly regarding anti-money laundering (AML) and counter-terrorism financing (CTF) measures.
  • Monitor any shifts in international sanctions that could impact the country’s regulatory obligations or standing in global financial systems.
  • Keep an eye on developments in Antigua and Barbuda’s relationship with international financial bodies and its alignment with global sanctions and anti-money laundering efforts.

Risk Assessment:

Medium Risk – Antigua and Barbuda presents a medium risk, primarily due to its offshore financial services industry, which has historically been a target for scrutiny and regulatory challenges. While not subject to direct sanctions, the country’s association with high-risk financial transactions requires businesses to conduct enhanced due diligence and closely monitor regulatory changes.

Argentina is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. While there are no broad sanctions against the country as a whole, Argentina has faced targeted sanctions in the past, particularly related to its nuclear and missile programs, and some individuals or entities in Argentina are subject to specific measures due to concerns related to corruption or terrorism financing.

Individuals/Entities under Targeted Sanctions:

Argentina does not have widespread sanctions, but certain individuals and entities within the country are subject to targeted measures. These sanctions are mainly from the United States, where specific individuals have been sanctioned for involvement in corruption, human rights abuses, or terrorist activities. Additionally, entities involved in Iran-related transactions or those linked to the country’s nuclear program may face restrictions from international regulatory bodies, including the U.S. and the EU.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Argentina, especially those involved in high-risk sectors like energy, finance, and government.
  • Review ownership structures to ensure compliance with international regulations, particularly those addressing money laundering and corruption.
  • Assess the source of funds and transactions to confirm they are not linked to sanctioned entities or individuals, particularly those tied to corruption or terrorism.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients and transactions linked to Argentina’s energy, defense, or nuclear sectors, as these areas may involve individuals or entities with past sanction risks.
  • Closely monitor any transactions involving politically exposed persons (PEPs) or entities with connections to Argentina’s government or military.
  • Investigate the ownership and control structures of entities involved in complex or high-value transactions, especially those with international exposure.
• Screen Against Sanctions Lists
  • Regularly screen clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and any national sanctions lists.
  • Pay particular attention to individuals and entities involved in sectors that are more prone to sanctions, including defense, nuclear technology, and government-related entities.
• Monitor for Regulatory Changes
  • Continuously monitor changes in Argentina’s political and economic environment, as shifts may lead to the imposition of new sanctions or regulatory measures.
  • Stay updated on Argentina’s international relations, particularly with the U.S., EU, and UN, as changes in these relationships could lead to new sanctions or restrictions.
  • Track any amendments to Argentina’s financial regulations, particularly those addressing anti-money laundering (AML) and counter-terrorism financing (CTF) efforts.

Risk Assessment:

Medium Risk – Argentina presents a medium risk due to the potential for targeted sanctions against individuals or entities involved in high-risk sectors. While the country is not broadly sanctioned, the presence of sectors like defense, energy, and government contracts warrants enhanced due diligence. Continuous monitoring for regulatory changes and adherence to international compliance standards is advised.

Armenia is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. However, Armenia’s geopolitical situation, particularly its close ties with Russia, means that it may be indirectly impacted by sanctions imposed on Russia. Armenia itself is not directly targeted by sanctions, but businesses and individuals linked to Armenia could face restrictions if they are involved in activities that are subject to broader international sanctions against Russia.

Individuals/Entities under Targeted Sanctions:

There are no significant individuals or entities in Armenia directly under international sanctions from the UN, EU, or U.S. However, Armenia's close relationship with Russia and its involvement in certain regions with political tensions may expose it to risks if entities or individuals with ties to Russia or other sanctioned jurisdictions are involved in activities that trigger secondary sanctions. Armenia may also face some targeted restrictions from specific countries or international bodies related to its position on regional conflicts, such as the Nagorno-Karabakh dispute.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Armenia, particularly those involved in sectors like defense, energy, or government contracts.
  • Review the ownership structures of entities to ensure compliance with both local and international regulations.
  • Assess the source of funds and transactions to ensure they are not linked to entities or individuals involved in sanctioned activities, especially those with ties to Russia or politically sensitive regions.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients and transactions linked to high-risk sectors, such as defense, energy, or state-owned enterprises in Armenia.
  • Scrutinize transactions involving individuals or entities connected to Armenia’s political or military structures, particularly in the context of the Nagorno-Karabakh conflict or other regional tensions.
  • Investigate the ownership and control structures of entities involved in large or unusual transactions, particularly those with international connections to Russia or other high-risk countries.
• Screen Against Sanctions Lists
  • Regularly screen clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and any national sanctions lists.
  • Pay attention to any individuals or entities with connections to Russia or other sanctioned countries, as they may face secondary sanctions or other restrictions.
• Monitor for Regulatory Changes
  • Monitor Armenia’s political and economic developments, particularly in relation to its ties with Russia and other countries subject to sanctions.
  • Stay updated on any changes in international sanctions that could affect Armenia or its business environment, particularly those related to Russia.
  • Track shifts in Armenia’s international relations, especially regarding its alignment with international sanctions regimes or its stance on regional conflicts.

Risk Assessment:

Medium Risk – Armenia presents a medium risk due to its geopolitical ties with Russia and its potential exposure to secondary sanctions. While Armenia is not directly sanctioned, its political and economic environment could lead to risks for businesses engaged in high-risk sectors or with connections to Russia or other sanctioned jurisdictions. Enhanced due diligence is recommended, particularly for transactions involving politically sensitive or high-risk sectors.

Austria is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a member of the European Union, Austria is required to adhere to EU sanctions regulations, which may include sanctions against specific individuals, entities, or sectors. Austria is generally considered a stable and compliant jurisdiction with a strong legal framework in place to meet international sanctions and financial regulations.

Individuals/Entities under Targeted Sanctions:

Austria itself is not under direct sanctions. However, the country does implement EU and UN sanctions, and as a result, certain individuals and entities within Austria, particularly those with links to sanctioned countries or activities, may be subject to targeted measures. Austria’s financial sector is also subject to scrutiny, especially in relation to anti-money laundering (AML) and counter-terrorism financing (CTF) compliance. There may be specific individuals or entities involved in sectors like finance or energy that could be subject to sanctions, but these are generally related to external activities.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers, especially those operating in sectors like finance, energy, and government.
  • Review the ownership structures of companies operating in Austria to ensure compliance with international regulations, particularly those relating to sanctions and money laundering.
  • Assess the source of funds and transactions to ensure they are not linked to individuals or entities subject to sanctions, particularly those with ties to high-risk jurisdictions.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients and transactions involving high-risk sectors such as banking, finance, and international trade, especially those with exposure to politically exposed persons (PEPs) or individuals/entities involved in high-risk activities.
  • Closely monitor any transactions involving entities or individuals connected to countries that are subject to EU, U.S., or UN sanctions, including those linked to the energy, defense, and technology sectors.
  • Investigate the ownership and control of entities involved in large, complex, or unusual transactions, particularly when these transactions cross international borders.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and any national sanctions lists.
  • Ensure that individuals or entities with any connections to sanctioned countries or activities, especially those with ties to sectors like energy, defense, or banking, are not involved in transactions.
• Monitor for Regulatory Changes
  • Continuously monitor for changes in Austria’s compliance with EU sanctions, particularly in light of evolving political and economic relations with sanctioned countries.
  • Stay updated on international sanctions that may affect Austria, especially those related to global trade, financial regulations, or political shifts in the EU.
  • Track any changes in Austria’s financial and regulatory landscape, especially regarding its stance on anti-money laundering (AML) and counter-terrorism financing (CTF).

Risk Assessment:

Low Risk – Austria is considered a low-risk country in terms of international sanctions, as it adheres strictly to EU sanctions and maintains a strong regulatory framework. However, businesses should remain vigilant and conduct due diligence, particularly in high-risk sectors or when dealing with individuals and entities with potential links to sanctioned jurisdictions. Regular monitoring of regulatory updates and sanctions lists is recommended.

Azerbaijan is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. While Azerbaijan itself is not under widespread sanctions, it is affected by regional dynamics and geopolitical issues. The country is aligned with Western energy interests and maintains relations with both the European Union and Russia, which sometimes subjects it to indirect scrutiny in the context of international sanctions against Russia or other regional actors.

Individuals/Entities under Targeted Sanctions:

Azerbaijan does not have significant individuals or entities directly targeted by international sanctions from the UN, EU, or U.S. However, certain individuals or entities within Azerbaijan could be indirectly affected due to their links with Russian interests or activities in regions under conflict, such as Nagorno-Karabakh. Specific individuals or companies involved in corruption, human rights abuses, or destabilizing activities in the region may be subject to sanctions from the U.S. or EU.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Azerbaijan, particularly those in high-risk sectors like energy, defense, and government.
  • Review ownership structures to ensure compliance with international regulations, especially those regarding anti-money laundering (AML) and counter-terrorism financing (CTF).
  • Assess the source of funds and transactions to ensure they are not linked to individuals or entities involved in sanctioned activities or corruption.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients and transactions involving the energy, defense, or government sectors in Azerbaijan, as these areas may involve individuals or entities with exposure to geopolitical risks.
  • Scrutinize any transactions related to the Nagorno-Karabakh region or those involving political entities with ties to Russia, as they may be indirectly impacted by sanctions.
  • Investigate the ownership and control of entities involved in large, complex, or cross-border transactions that may involve high-risk jurisdictions.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other national sanctions lists.
  • Pay close attention to individuals or entities linked to Russia or other sanctioned countries, as they may be subject to secondary sanctions or restrictions.
• Monitor for Regulatory Changes
  • Stay updated on any political or economic shifts in Azerbaijan, particularly regarding its relations with Russia, the EU, and the U.S.
  • Monitor changes in international sanctions regimes that could affect Azerbaijan, especially in response to the country's involvement in regional conflicts or its alignment with global powers.
  • Track any changes in Azerbaijan’s regulatory framework, particularly those addressing financial transparency, money laundering, and counter-terrorism financing.

Risk Assessment:

Medium Risk – Azerbaijan presents a medium risk due to its geopolitical positioning and involvement in regional conflicts. While the country is not directly targeted by comprehensive sanctions, it is indirectly affected by its relationships with Russia and other international actors. Enhanced due diligence is recommended for transactions involving politically sensitive sectors or regions with ties to potential secondary sanctions. Regular monitoring of international sanctions and regulatory changes is essential.

Bahrain is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a member of the Gulf Cooperation Council (GCC), Bahrain is generally aligned with U.S. and EU interests in the Middle East. However, the country has faced scrutiny in the past for its human rights record, particularly in relation to political unrest and civil rights issues. Despite this, Bahrain is not under broad international sanctions, though some individuals and entities may face targeted measures from specific countries.

Individuals/Entities under Targeted Sanctions:

Bahrain itself is not under international sanctions, but certain individuals and entities within the country have been subject to targeted sanctions, particularly from the United States and the European Union. These sanctions are typically imposed on individuals connected to human rights violations, political repression, or involvement in activities undermining regional stability. The U.S. has imposed travel bans and asset freezes on some Bahraini officials involved in the suppression of protests or political dissent.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Bahrain, especially those in high-risk sectors such as finance, energy, and government.
  • Review ownership structures of companies operating in Bahrain to ensure compliance with international regulations, particularly in relation to money laundering and human rights.
  • Assess the source of funds and transactions to confirm they are not linked to individuals or entities involved in sanctioned activities or violations of international norms.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients and transactions linked to Bahrain’s government, security services, or military sectors, as these areas may involve individuals or entities that could be subject to targeted sanctions.
  • Scrutinize transactions involving politically exposed persons (PEPs) or individuals with ties to government officials or the royal family.
  • Investigate the ownership and control structures of entities involved in large, complex, or high-risk transactions, particularly those with links to politically sensitive industries.
• Screen Against Sanctions Lists
  • Regularly screen clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other national sanctions lists.
  • Pay particular attention to individuals or entities linked to human rights violations, political unrest, or actions that may undermine regional stability.
• Monitor for Regulatory Changes
  • Stay updated on any political or economic changes in Bahrain, particularly concerning its relations with the U.S. and EU, and the ongoing political situation within the country.
  • Monitor any developments in Bahrain’s stance on human rights, as this may affect the imposition of new sanctions or international scrutiny.
  • Track changes in Bahrain’s financial regulations, particularly regarding anti-money laundering (AML) and counter-terrorism financing (CTF).

Risk Assessment:

Medium Risk – Bahrain presents a medium risk due to its political situation, particularly regarding human rights and political repression. While the country is not broadly sanctioned, there are targeted measures in place against certain individuals. Enhanced due diligence is recommended, particularly when engaging with the government, security forces, or entities linked to politically sensitive sectors. Regular monitoring of both regulatory changes and international sanctions is necessary.

Bangladesh is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. However, like many countries, it is subject to various international regulations and financial compliance standards. Bangladesh has faced scrutiny in relation to issues such as corruption, money laundering, and human rights concerns, but these do not result in broad sanctions. The country does face targeted measures for specific individuals or entities linked to these issues, particularly in the context of governance and the judiciary.

Individuals/Entities under Targeted Sanctions:

Bangladesh itself is not under comprehensive sanctions, but certain individuals and entities have faced targeted measures, especially from the United States. These sanctions are generally related to corruption, human rights abuses, or ties to terrorism. Notably, the U.S. has sanctioned some Bangladeshi officials involved in alleged human rights violations or anti-democratic activities, such as election-related violence or the suppression of political opposition. Additionally, entities linked to the country’s financial sector may face scrutiny for anti-money laundering (AML) violations.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Bangladesh, particularly those involved in sectors like finance, government, or defense.
  • Review ownership structures and operations to ensure compliance with international regulations, particularly in relation to money laundering and corruption.
  • Assess the source of funds and transactions to ensure they are not linked to sanctioned individuals, entities, or sectors, especially those with allegations of corruption or human rights abuses.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients and transactions in high-risk sectors, including government, military, and the financial services industry, where there may be connections to corruption or human rights violations.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to Bangladesh’s ruling elite or controversial sectors.
  • Investigate ownership and control structures of entities involved in complex or high-value transactions, particularly in sectors vulnerable to financial crimes, such as banking or real estate.
• Screen Against Sanctions Lists
  • Regularly screen clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other national sanctions lists.
  • Pay particular attention to individuals or entities with links to human rights abuses, corruption, or ties to terrorism, as these may face sanctions from the U.S. or other countries.
• Monitor for Regulatory Changes
  • Stay updated on any political or economic developments in Bangladesh, particularly those related to governance, the judicial system, or election integrity, as they may influence future sanctions or regulatory actions.
  • Monitor changes in Bangladesh’s financial and regulatory framework, particularly regarding anti-money laundering (AML) and counter-terrorism financing (CTF) measures.
  • Track any updates to international sanctions regimes that may impact Bangladesh, particularly those related to human rights or corruption.

Risk Assessment:

Medium Risk – Bangladesh is considered a medium-risk country due to issues related to corruption, human rights abuses, and political instability, which may result in targeted sanctions against individuals or entities. While the country itself is not broadly sanctioned, businesses should conduct enhanced due diligence, particularly when engaging with sectors or individuals with known exposure to financial crimes or political risks. Continuous monitoring of regulatory changes and sanctions lists is recommended.

Barbados is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country maintains a relatively stable political environment and is not directly affected by broad-based international sanctions. However, Barbados, like other countries, must comply with international standards for financial regulations, including anti-money laundering (AML) and counter-terrorism financing (CTF) requirements, and may be scrutinized in relation to these areas.

Individuals/Entities under Targeted Sanctions:

Barbados itself is not under any targeted sanctions by major international bodies. However, certain individuals and entities within Barbados may face targeted sanctions from specific countries or organizations, particularly if they are linked to money laundering activities, terrorist financing, or other illicit financial activities. Barbados has cooperated with international efforts to combat these issues but may still be subject to scrutiny due to its status as an offshore financial center.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Barbados, particularly those involved in financial services, real estate, and offshore activities.
  • Review ownership structures of companies and entities in Barbados to ensure compliance with international regulations, particularly concerning AML and CTF standards.
  • Assess the source of funds and transactions to confirm they are not linked to illicit activities or individuals/entities subject to sanctions.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients and transactions in sectors with a higher risk of financial crime, such as banking, offshore finance, or real estate.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with international ties or links to higher-risk jurisdictions.
  • Investigate the ownership and control of entities involved in complex or high-value transactions, especially those that involve cross-border financial flows.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and any national sanctions lists.
  • Ensure that no individuals or entities involved in transactions with Barbados are linked to money laundering, terrorist financing, or other criminal activities.
• Monitor for Regulatory Changes
  • Continuously monitor changes in Barbados’ financial regulations, particularly in relation to AML and CTF compliance.
  • Stay updated on developments in international regulations, especially those that could affect Barbados’ offshore financial sector or result in new scrutiny from international bodies.
  • Track any shifts in Barbados’ international relations, particularly with the U.S., EU, or other key regulatory bodies that may affect its financial reputation or regulatory compliance.

Risk Assessment:

Low Risk – Barbados presents a low risk in terms of international sanctions. The country is generally not subject to broad sanctions, and there is no significant indication of targeted restrictions against it. However, due diligence is still recommended, especially for entities operating in offshore finance or other high-risk sectors. Regular monitoring of regulatory changes and compliance standards is advised.

Belarus is currently subject to comprehensive international sanctions from major regulatory bodies such as the United Nations, the European Union, and the United States. These sanctions have been imposed due to Belarus' political repression, human rights violations, and its support for Russia's actions, particularly regarding the invasion of Ukraine. The sanctions target key sectors of the economy, including finance, energy, and defense, as well as specific individuals and entities within the country. Belarus is one of the most heavily sanctioned countries in Europe due to its government's actions.

Individuals/Entities under Targeted Sanctions:

Numerous individuals and entities in Belarus are under targeted sanctions. These sanctions include asset freezes, travel bans, and restrictions on business activities. Key targets include government officials, members of the military, state-owned enterprises, and those involved in the crackdown on political dissent and human rights abuses. Belarusian state-owned companies, particularly in sectors like defense, finance, and energy, are also subject to restrictions by the EU, U.S., and other countries. Additionally, Belarus has been sanctioned due to its close ties with Russia and its role in regional instability.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Belarus, particularly those involved in high-risk sectors such as finance, defense, and state-owned enterprises.
  • Review ownership structures and operations of entities based in Belarus to ensure compliance with international regulations, particularly those concerning sanctions and money laundering.
  • Assess the source of funds and transactions to ensure they are not linked to sanctioned individuals or entities, especially those tied to government activities or the military.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients and transactions involving politically sensitive sectors in Belarus, including government contracts, defense, and energy.
  • Scrutinize transactions involving politically exposed persons (PEPs) or individuals with ties to the Belarusian government, military, or the state security apparatus.
  • Investigate the ownership and control of entities involved in large, complex, or cross-border transactions, particularly those with connections to Belarusian state-owned companies or sanctioned industries.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other national sanctions lists.
  • Pay close attention to individuals or entities with links to Belarusian government officials, military, or industries subject to international sanctions. Ensure that no business activities are being conducted with sanctioned individuals or entities.
• Monitor for Regulatory Changes
  • Stay updated on changes in Belarus' political situation, particularly those related to its relations with Russia and its domestic human rights practices, as these may affect the scope and nature of international sanctions.
  • Monitor developments in the international sanctions landscape, particularly those from the EU, U.S., and UN, as these may result in new restrictions or modifications to existing measures.
  • Track any changes in Belarus’ financial and regulatory environment, particularly those affecting sectors like finance, energy, or defense that are most vulnerable to sanctions.

Risk Assessment:

High Risk – Belarus poses a high risk in terms of international sanctions. The country is heavily sanctioned by the EU, U.S., and other bodies due to its government’s actions regarding political repression, human rights abuses, and its involvement in regional conflicts. Due diligence should be robust and thorough when engaging with any entities or individuals in Belarus, particularly in high-risk sectors such as finance, energy, and defense. Constant monitoring of regulatory and geopolitical changes is necessary to ensure compliance with evolving sanctions.

Belgium is not subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a member of the European Union, Belgium adheres to EU sanctions and implements international regulations regarding finance, trade, and international relations. Belgium's compliance with international sanctions regulations is generally strong, and it has established frameworks for addressing issues such as money laundering and counter-terrorism financing. However, businesses in Belgium may be indirectly affected by EU-wide sanctions, particularly in relation to sectors such as finance, energy, and defense.

Individuals/Entities under Targeted Sanctions:

Belgium is not itself under any targeted sanctions, but like other EU member states, it enforces sanctions that are imposed by the European Union, the United Nations, and other international bodies. Certain individuals and entities in Belgium may be subject to EU or UN sanctions due to links with sanctioned countries, illicit activities, or violations of international law. Belgian individuals or entities linked to corruption, terrorism, or human rights violations may also face targeted sanctions by other countries, including the U.S.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers in Belgium, particularly in sectors such as finance, defense, and government.
  • Review the ownership structures of companies operating in Belgium to ensure compliance with relevant EU regulations, including anti-money laundering (AML) and counter-terrorism financing (CTF).
  • Assess the source of funds and transactions to ensure they are not linked to individuals or entities subject to sanctions, particularly those in high-risk sectors.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients and transactions in politically sensitive sectors such as banking, finance, defense, and energy.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to governments or entities involved in sanctioned activities.
  • Investigate the ownership and control of entities involved in large, complex, or unusual transactions, particularly in high-risk industries like finance or technology.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Pay particular attention to individuals and entities linked to high-risk jurisdictions or those involved in activities such as terrorism, money laundering, or corruption.
• Monitor for Regulatory Changes
  • Stay updated on changes in Belgium’s compliance with EU and UN sanctions, particularly those that may affect its financial sector or cross-border trade relationships.
  • Monitor the political and economic landscape in Belgium and the EU for any shifts that may result in changes to the sanctions framework.
  • Track the enforcement of international regulations in Belgium, particularly in relation to financial crimes and sanctions compliance.

Risk Assessment:

Low Risk – Belgium presents a low risk in terms of international sanctions, as it adheres to EU regulations and international norms. The country itself is not under sanctions, and its strong regulatory environment ensures compliance with global standards. However, businesses should remain diligent when engaging in sectors like finance, energy, or defense, and ensure continuous monitoring of regulatory changes and global sanctions lists.

Belize is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. However, Belize, as a member of the international community, is required to comply with various international regulations, including anti-money laundering (AML) and counter-terrorism financing (CTF) standards. Belize has faced scrutiny in the past for its role in offshore finance, but it is not under broad-based international sanctions. The country is generally considered a financial services hub for certain industries, including international business companies (IBCs), which can sometimes be viewed as higher risk.

Individuals/Entities under Targeted Sanctions:

Belize itself is not subject to international sanctions, but certain individuals or entities in Belize may face targeted sanctions due to their connections with illicit financial activities or other international legal violations. These sanctions are typically imposed by countries such as the U.S., which may target individuals or entities involved in money laundering, corruption, or illicit financial flows. As an offshore financial center, Belize may also be scrutinized in relation to global efforts to combat tax evasion or financial crimes.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Belize, particularly those involved in financial services, offshore companies, or real estate.
  • Review the ownership structures of entities based in Belize to ensure compliance with international regulations regarding money laundering, tax evasion, and counter-terrorism financing.
  • Assess the source of funds and transactions to ensure they are not linked to sanctioned individuals, illicit activities, or politically exposed persons (PEPs).
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients and transactions linked to the financial services sector in Belize, particularly those involving offshore companies, trusts, or entities with complex ownership structures.
  • Scrutinize transactions involving PEPs, especially those with potential exposure to higher-risk jurisdictions or financial systems.
  • Investigate the ownership and control structures of entities involved in large, cross-border transactions or high-value deals, particularly those linked to industries at risk for financial crimes.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Pay special attention to individuals and entities with links to corruption, money laundering, or other illicit financial activities, which may be subject to sanctions from jurisdictions like the U.S.
• Monitor for Regulatory Changes
  • Stay updated on changes in Belize’s regulatory framework, particularly those regarding financial transparency, anti-money laundering (AML), and counter-terrorism financing (CTF).
  • Monitor developments in Belize’s offshore financial sector, as international pressure and regulations regarding tax havens may impact the country’s financial services industry.
  • Track changes in global and regional sanctions regimes, as well as any shifts in Belize’s financial or political landscape that may affect its international compliance obligations.

Risk Assessment:

Medium Risk – Belize presents a medium risk due to its offshore financial services sector and past scrutiny related to financial crimes. While the country itself is not under international sanctions, its role as a financial hub means that certain entities or individuals in Belize could be exposed to international sanctions, particularly in relation to money laundering, corruption, or other illicit financial activities. Enhanced due diligence is recommended for transactions involving the financial services sector, real estate, or offshore business activities. Continuous monitoring of regulatory and sanctions lists is advised.

Benin is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country maintains stable political and economic relations internationally and is not directly impacted by broad sanctions. Benin is a member of various international organizations, including the United Nations and the African Union, and adheres to regional and global agreements. However, the country must comply with international regulations concerning money laundering and counter-terrorism financing (CTF), and certain individuals or entities may be subject to targeted sanctions related to specific activities.

Individuals/Entities under Targeted Sanctions:

Benin itself is not subject to any international sanctions, but some individuals or entities within the country may face targeted measures, particularly from the United States or the European Union. These sanctions may be related to corruption, human rights violations, or ties to international criminal activities. Benin’s financial institutions and key sectors are not under widespread sanctions, but businesses should remain vigilant for any developments or designations related to sanctioned individuals or organizations.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Benin, particularly those in sectors like government, finance, and infrastructure.
  • Review the ownership structures of entities operating in Benin to ensure compliance with international regulations, especially concerning anti-money laundering (AML) and counter-terrorism financing (CTF).
  • Assess the source of funds and transactions to ensure they are not linked to individuals or entities subject to sanctions, particularly those with ties to illicit activities or corruption.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients and transactions in higher-risk sectors, such as government contracts, banking, or infrastructure projects.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with potential links to corruption or human rights violations.
  • Investigate the ownership and control structures of entities involved in large, cross-border, or complex transactions, particularly in sectors susceptible to financial crimes.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Pay particular attention to individuals or entities with links to corruption, terrorism, or other illicit financial activities that may result in sanctions from the U.S., EU, or other countries.
• Monitor for Regulatory Changes
  • Stay updated on changes in Benin’s regulatory environment, particularly related to financial transparency, anti-money laundering (AML), and counter-terrorism financing (CTF).
  • Monitor any shifts in the political or economic landscape in Benin that may lead to changes in its international relations or sanctions status.
  • Track any updates from the UN, EU, or U.S. regarding potential new sanctions or designations involving individuals or entities in Benin.

Risk Assessment:

Low Risk – Benin presents a low risk in terms of international sanctions. The country is not subject to broad international sanctions, and there are no major concerns regarding compliance with global financial regulations. However, as with any jurisdiction, businesses should remain vigilant for any updates on targeted sanctions related to individuals or entities involved in corruption, money laundering, or illicit activities. Regular monitoring of regulatory changes and sanctions lists is recommended.

Bhutan is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country maintains a neutral foreign policy and generally avoids involvement in international conflicts or political tensions. Bhutan is a member of the United Nations and adheres to its international obligations but does not face significant sanctions. The country's economy is small, and it is primarily focused on sustainable development, agriculture, and tourism, with limited exposure to sectors that would typically attract international sanctions.

Individuals/Entities under Targeted Sanctions:

Bhutan is not under any targeted sanctions, nor are there prominent individuals or entities in the country currently listed on international sanctions lists. Bhutan's political stability and non-involvement in international disputes have kept it outside of the scope of targeted sanctions by the United Nations, European Union, or United States. However, businesses engaging with Bhutan should remain cautious and monitor for any developments in international relations that could lead to sanctions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Bhutan, particularly those involved in government projects, tourism, and agriculture.
  • Review the ownership structures of entities in Bhutan to ensure compliance with international regulations, especially concerning money laundering, counter-terrorism financing (CTF), and other global standards.
  • Assess the source of funds and transactions to ensure that they do not involve illicit activities or links to sanctioned individuals or entities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients or transactions involving large-scale projects or those related to sensitive sectors such as government contracts or energy.
  • Scrutinize transactions involving politically exposed persons (PEPs) or individuals with connections to high-level government or business sectors.
  • Investigate ownership and control structures of entities involved in large, cross-border transactions or high-value deals.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that no business activities are being conducted with individuals or entities from Bhutan that are connected to illicit activities or politically sensitive sectors.
• Monitor for Regulatory Changes
  • Continuously monitor changes in Bhutan’s regulatory environment, particularly in relation to financial transparency, anti-money laundering (AML), and counter-terrorism financing (CTF).
  • Track any shifts in Bhutan’s international relations, particularly with neighboring countries or global powers, that could affect the country’s sanctions status or lead to new restrictions.
  • Keep informed of any political developments in Bhutan that may impact its stability or lead to potential risks for international business engagements.

Risk Assessment:

Low Risk – Bhutan presents a low risk in terms of international sanctions. The country is politically stable, neutral in international relations, and not subject to any broad-based or targeted sanctions. While Bhutan does not face significant international scrutiny, businesses should still conduct regular due diligence, especially for large or cross-border transactions, to ensure compliance with global financial regulations. Monitoring of potential geopolitical shifts and regulatory updates is recommended.

Bolivia is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. While Bolivia has faced certain restrictions or measures from individual countries over specific issues, these are typically not as extensive as sanctions applied to other countries. Bolivia’s political stance is independent, and while it has occasionally had tensions with certain international powers, particularly in relation to its policies on natural resources, it does not face broad-based sanctions. Bolivia is a member of the United Nations and adheres to international agreements related to peace, security, and human rights.

Individuals/Entities under Targeted Sanctions:

There are no widespread international sanctions currently affecting Bolivia as a country. However, certain individuals and entities in Bolivia may face targeted sanctions, primarily from the United States. These sanctions could be in response to issues such as drug trafficking, corruption, or actions that undermine democratic processes. Bolivian individuals, companies, or officials linked to illicit activities or violations of international law may be subject to asset freezes, travel bans, or trade restrictions, especially in relation to the U.S. or specific regional sanctions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Bolivia, particularly those involved in sectors like government, mining, energy, and agriculture.
  • Review the ownership structures of entities operating in Bolivia to ensure compliance with relevant international regulations, including anti-money laundering (AML) and counter-terrorism financing (CTF) laws.
  • Assess the source of funds and transactions to ensure they are not linked to illicit activities, corruption, or individuals/entities under sanctions.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients or transactions involving politically sensitive sectors, such as government contracts, natural resource extraction (e.g., lithium, gas), or high-value infrastructure projects.
  • Scrutinize transactions involving politically exposed persons (PEPs) or individuals with connections to Bolivia’s government or military, particularly in cases where there are concerns about corruption or human rights violations.
  • Investigate ownership and control structures of entities involved in large, cross-border transactions, particularly in sectors that may be vulnerable to illicit financial flows.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Pay particular attention to individuals and entities with links to drug trafficking, corruption, or political activities that could lead to sanctions.
• Monitor for Regulatory Changes
  • Stay updated on Bolivia’s political and economic landscape, particularly with regard to its relationships with major international powers like the U.S. and the EU, which may influence the country’s exposure to sanctions.
  • Monitor any changes in Bolivia’s involvement in international treaties or trade agreements that could impact its sanctions status or global standing.
  • Track updates on Bolivia’s regulatory framework for financial transparency and anti-money laundering (AML) compliance, as these may impact business operations in the country.

Risk Assessment:

Medium Risk – Bolivia presents a medium risk in terms of international sanctions. While the country is not broadly sanctioned, there are specific individuals and entities in Bolivia that may be subject to targeted measures, especially those linked to corruption, drug trafficking, or other illicit activities. Businesses should be vigilant, particularly in sectors such as government, mining, and energy, and apply enhanced due diligence for transactions involving high-risk entities or individuals. Monitoring regulatory changes and international relations will be crucial to managing potential sanctions exposure.

Bosnia and Herzegovina is not currently under comprehensive international sanctions from major regulatory bodies such as the United Nations, the European Union, or the United States. However, the country remains subject to targeted sanctions imposed by the European Union and other international bodies in relation to its complex post-war political environment. The EU has implemented sanctions against individuals and entities involved in activities that undermine the stability of Bosnia and Herzegovina or those associated with human rights violations, corruption, and obstruction of peace efforts. Despite these restrictions, Bosnia and Herzegovina itself is not broadly sanctioned as a nation.

Individuals/Entities under Targeted Sanctions:

Certain individuals and entities within Bosnia and Herzegovina are under targeted sanctions imposed by the European Union, the United States, and the United Nations. These sanctions typically apply to political figures, business leaders, and other individuals implicated in activities that destabilize the country, such as corruption, obstruction of the peace process, or involvement in criminal activities. These sanctions often include asset freezes, travel bans, and restrictions on business dealings. As Bosnia and Herzegovina continues to evolve politically, the list of sanctioned individuals and entities may change.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Bosnia and Herzegovina, particularly those involved in sensitive sectors like government contracts, banking, and energy.
  • Review the ownership structures of companies operating in Bosnia and Herzegovina to ensure compliance with international standards, especially concerning anti-money laundering (AML) and counter-terrorism financing (CTF).
  • Assess the source of funds and transactions to ensure they are not linked to sanctioned individuals or entities or associated with activities that violate international norms.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients and transactions in higher-risk sectors, such as government procurement, energy, and defense.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with links to entities or individuals under EU, UN, or U.S. sanctions.
  • Investigate the ownership and control of entities involved in large, complex, or high-value transactions, particularly if there are concerns about corruption or connections to political instability.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that no transactions or business relationships are made with individuals or entities subject to international sanctions, especially those related to corruption, organized crime, or obstruction of the peace process.
• Monitor for Regulatory Changes
  • Stay updated on changes in Bosnia and Herzegovina’s political environment and international relations, as shifts in the political landscape could lead to new sanctions or targeted measures.
  • Monitor developments in the EU and the UN related to Bosnia and Herzegovina, especially regarding any potential changes in the sanctions regime or additional designations of individuals and entities.
  • Track updates in Bosnia and Herzegovina’s regulatory framework concerning financial transparency, anti-money laundering (AML), and counter-terrorism financing (CTF), as these could influence the risk landscape.

Risk Assessment:

Medium Risk – Bosnia and Herzegovina presents a medium risk in terms of international sanctions. While the country is not broadly sanctioned, targeted sanctions are in place for individuals and entities associated with political instability, corruption, or other criminal activities. Due diligence is essential, particularly in sectors that may involve government contracts, energy, and defense. Regular monitoring of political developments and sanctions lists is recommended to manage potential risks associated with transactions in or involving Bosnia and Herzegovina.

Botswana is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country maintains a stable political environment and strong international relations, particularly with Western countries and regional bodies in Africa. Botswana is often regarded as one of the most stable democracies in Africa, and it actively participates in global peacekeeping efforts and regional cooperation. While it adheres to international conventions and standards, it is not under any widespread sanctions.

Individuals/Entities under Targeted Sanctions:

There are no individuals or entities in Botswana that are currently under targeted sanctions by major international bodies, including the UN, EU, or U.S. The country does not have a history of significant involvement in activities that would attract international sanctions. However, businesses should remain aware that individuals or entities with indirect links to illicit activities or global sanctions lists may still pose potential risks, and due diligence should be conducted accordingly.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Botswana, especially those involved in high-value sectors such as mining, government contracts, and agriculture.
  • Review ownership structures of companies operating in Botswana to ensure compliance with global financial regulations, including anti-money laundering (AML) and counter-terrorism financing (CTF) standards.
  • Assess the source of funds and transactions to ensure they are legitimate and not connected to illicit activities or sanctioned individuals/entities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving sectors that may carry higher risks, such as mining, government procurement, or large cross-border transactions.
  • Scrutinize dealings with politically exposed persons (PEPs) or individuals with links to industries or regions known for higher corruption risks.
  • Investigate ownership and control structures of entities involved in larger, more complex or high-risk transactions, especially in sectors with significant public sector involvement.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business engagements are not made with individuals or entities listed for reasons such as corruption, money laundering, or connections to organized crime.
• Monitor for Regulatory Changes
  • Stay updated on changes in Botswana’s political and economic environment, particularly in relation to the mining industry, government policies, and regional security matters that could impact the country’s international standing.
  • Monitor for any changes in international relations or sanctions regimes that may indirectly affect Botswana, especially if there is a shift in its economic or trade policies.
  • Track updates on Botswana’s legal framework regarding financial transparency, anti-money laundering (AML), and counter-terrorism financing (CTF) practices.

Risk Assessment:

Low Risk – Botswana presents a low risk in terms of international sanctions. The country enjoys political stability, strong governance, and good relations with the international community. It is not subject to any broad sanctions and does not have high-risk sectors that would generally attract international scrutiny. However, businesses should still ensure standard due diligence practices, particularly for high-value transactions or dealings with PEPs. Monitoring for regulatory changes is recommended to manage any potential emerging risks.

Brazil is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country is a key player in global trade, economics, and diplomacy, and it is generally considered a stable democracy. Brazil is a member of various international organizations, including the United Nations, the World Trade Organization (WTO), and the Organization of American States (OAS). While there are no broad sanctions, Brazil does face some sectoral restrictions, especially in relation to environmental concerns, corruption, and criminal activities in certain industries like mining and deforestation.

Individuals/Entities under Targeted Sanctions:

Brazil itself is not under any widespread sanctions, but certain individuals and entities within the country may face targeted sanctions from the United States, European Union, or other countries. These sanctions are typically related to issues such as corruption, drug trafficking, and human rights violations. For example, Brazil has been associated with international measures against individuals or groups involved in illegal activities in the Amazon region, including deforestation and environmental degradation. The U.S. has imposed sanctions on specific individuals linked to criminal organizations or actions that undermine democratic institutions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Brazil, particularly those involved in sensitive sectors such as mining, agriculture, energy, and government.
  • Review the ownership structures of entities operating in Brazil to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) standards.
  • Assess the source of funds and transactions to ensure they are not linked to corrupt activities, criminal organizations, or individuals/entities under sanctions.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients or transactions in higher-risk sectors, such as those related to the Amazon region, illegal logging, mining, or government contracts.
  • Scrutinize transactions involving politically exposed persons (PEPs) or individuals with ties to corruption, environmental destruction, or other illicit activities.
  • Investigate ownership and control structures of entities involved in large, cross-border, or high-value transactions, especially those in politically sensitive sectors.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure business engagements are not made with individuals or entities connected to illicit activities such as corruption, deforestation, or illegal drug trade.
• Monitor for Regulatory Changes
  • Stay updated on changes in Brazil’s political, environmental, and economic landscape, particularly in sectors prone to corruption, illegal activities, or environmental exploitation.
  • Monitor changes in international relations or sanctions regimes that may affect Brazil, especially in relation to environmental policies or political developments that could lead to sanctions.
  • Track updates on Brazil’s regulatory framework regarding financial transparency, anti-money laundering (AML), and counter-terrorism financing (CTF).

Risk Assessment:

Medium Risk – Brazil presents a medium risk in terms of international sanctions. While the country is not broadly sanctioned, there are targeted measures against individuals and entities involved in corruption, environmental crimes, or illegal activities. Due diligence should be applied carefully, particularly in sectors linked to high-profile risks like government contracting, mining, and deforestation. Monitoring regulatory changes, political developments, and sanctions lists is essential to managing exposure to potential risks related to illicit activities or emerging sanctions.

Brunei is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country maintains a neutral foreign policy and is not involved in significant international conflicts. It has a stable political environment, with an absolute monarchy led by Sultan Hassanal Bolkiah. Brunei has good relations with both Western and regional countries, and it adheres to international norms, particularly in the areas of human rights and economic cooperation. There are no broad-based sanctions against Brunei.

Individuals/Entities under Targeted Sanctions:

Brunei does not have individuals or entities under international targeted sanctions from the United Nations, the European Union, or the United States. The country’s leadership and key sectors generally operate in compliance with international law and regulations. However, businesses should be aware that individuals with indirect links to illicit activities or to international sanctions lists in other countries may still present risks in some cases. As Brunei is a small, wealthy nation with significant oil and gas resources, due diligence should be applied in industries with a potential for corruption or money laundering.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Brunei, particularly those involved in the oil and gas sector, finance, and government projects.
  • Review ownership structures of entities operating in Brunei to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) standards.
  • Assess the source of funds and transactions to ensure they are not linked to illicit activities or sanctioned individuals/entities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for clients or transactions involving high-value sectors, such as energy, government procurement, and large financial deals.
  • Scrutinize transactions involving politically exposed persons (PEPs) or individuals with links to Brunei’s royal family or high-level government officials.
  • Investigate ownership and control structures of entities involved in large, complex, or cross-border transactions, especially in sectors with potential exposure to corruption risks.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure business engagements are not made with individuals or entities listed for reasons such as corruption, human rights violations, or links to criminal activities.
• Monitor for Regulatory Changes
  • Stay updated on changes in Brunei’s political and economic environment, especially related to oil, gas, and finance sectors that may expose businesses to sanctions risks.
  • Monitor shifts in Brunei’s international relations and any new sanctions regimes that may affect the country’s global standing.
  • Track updates on Brunei’s regulatory framework concerning financial transparency, anti-money laundering (AML), and counter-terrorism financing (CTF).

Risk Assessment:

Low Risk – Brunei presents a low risk in terms of international sanctions. The country enjoys political stability, strong governance, and a lack of involvement in conflicts that could attract international sanctions. While Brunei does not face any broad sanctions or significant exposure to international scrutiny, businesses should conduct regular due diligence, especially in high-risk sectors such as energy and government contracts, to mitigate any potential risks associated with corruption or financial crimes. Monitoring regulatory changes and shifts in international relations will help ensure compliance with global standards.

Bulgaria is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a European Union member state, Bulgaria adheres to the EU's regulations and sanctions framework, which is aligned with broader international norms. Bulgaria has a stable political and economic environment, though certain sectors such as banking and energy may face scrutiny due to historical challenges related to corruption and organized crime. Bulgaria has been involved in regional and international cooperation efforts, and it is not under any broad sanctions.

Individuals/Entities under Targeted Sanctions:

While Bulgaria itself is not under international sanctions, certain individuals and entities within the country may be subject to targeted sanctions imposed by the European Union, the United States, or other jurisdictions. These sanctions typically apply to individuals involved in corruption, organized crime, or activities that undermine the democratic process or rule of law. For example, specific Bulgarian individuals may be on the U.S. Treasury’s Specially Designated Nationals (SDN) list due to involvement in corrupt practices or organized criminal activities. Entities linked to such individuals may also face restrictions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Bulgaria, especially in sectors such as banking, energy, and government contracting.
  • Review ownership structures of companies operating in Bulgaria to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) standards.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or entities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving sectors with higher corruption risks, such as government contracts, real estate, and public procurement.
  • Scrutinize transactions involving politically exposed persons (PEPs) or individuals with links to Bulgarian officials, organized crime, or corruption.
  • Investigate ownership and control structures of entities involved in large or complex cross-border transactions, particularly in high-risk sectors.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that no transactions are made with individuals or entities listed for reasons such as corruption, organized crime, or other illicit activities.
• Monitor for Regulatory Changes
  • Stay updated on political, economic, and regulatory changes in Bulgaria, especially in sectors such as energy, banking, and public procurement, which may have higher risks of illicit activity.
  • Monitor for any changes in Bulgaria's alignment with EU sanctions policies or any changes in its international relations that could impact its exposure to new sanctions or targeted measures.
  • Track updates to Bulgaria’s regulatory framework concerning financial transparency, anti-money laundering (AML), and counter-terrorism financing (CTF).

Risk Assessment:

Medium Risk – Bulgaria presents a medium risk in terms of international sanctions. While the country is not under comprehensive sanctions, there are targeted sanctions against individuals and entities involved in corruption, organized crime, or violations of democratic principles. Businesses should exercise due diligence in sectors with higher corruption risks and be aware of the potential for exposure to individuals or entities on sanctions lists. Monitoring political developments and sanctions updates is essential to mitigate potential risks related to financial crimes or politically motivated sanctions.

Burkina Faso is currently subject to international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, and the United States. Following the military coup in 2022 and the ongoing instability, the country has faced targeted measures, including asset freezes and travel bans on individuals associated with the coup and the military-led government. The United Nations and the European Union have imposed these sanctions in response to the deterioration of democratic governance, human rights violations, and the disruption of the constitutional order.

Individuals/Entities under Targeted Sanctions:

Several individuals in Burkina Faso, including members of the military leadership and officials connected to the 2022 coup, are subject to targeted sanctions. These measures include asset freezes and travel bans, as well as restrictions on dealing with entities controlled by or linked to the military regime. The sanctions are primarily imposed by the European Union and the United States, but they could evolve based on further developments in the country’s political environment.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Burkina Faso, particularly those involved in sectors such as government contracts, natural resources, and defense.
  • Review the ownership structures of companies operating in Burkina Faso to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are not linked to sanctioned individuals or entities connected to the military regime.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving individuals or entities with potential links to the military government or sectors associated with the regime’s activities, such as defense, security, and public procurement.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to the coup leadership or key military figures.
  • Investigate ownership and control structures of entities involved in high-value or cross-border transactions, particularly in industries with significant government involvement or potential corruption risks.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not conducted with individuals or entities subject to sanctions for reasons such as political destabilization, human rights violations, or involvement in the coup.
• Monitor for Regulatory Changes
  • Stay updated on changes in Burkina Faso’s political situation, particularly regarding the military government’s policies and international relations.
  • Monitor any new sanctions or targeted measures imposed by international organizations, particularly if there is a further breakdown in governance or an escalation of human rights abuses.
  • Track developments regarding Burkina Faso’s regulatory environment, particularly in sectors that may be impacted by the ongoing political instability.

Risk Assessment:

High Risk – Burkina Faso presents a high risk in terms of international sanctions. Due to the military coup and the resulting instability, the country faces significant targeted sanctions. Businesses should exercise caution and conduct thorough due diligence, especially when dealing with government contracts, sectors tied to military operations, or entities potentially linked to sanctioned individuals. Close monitoring of regulatory changes and political developments is critical to mitigate risks and ensure compliance with international sanctions regimes.

Burundi is currently subject to international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, and the United States. These sanctions stem from concerns over human rights violations, political repression, and the violent suppression of opposition groups during and after the 2015 political crisis. The sanctions have included arms embargoes, asset freezes, and travel bans on individuals and entities associated with the government and military. These measures remain in place due to the ongoing concerns about the country's political and human rights situation.

Individuals/Entities under Targeted Sanctions:

Burundi has several individuals and entities that are subject to targeted sanctions, including asset freezes, travel bans, and restrictions on financial transactions. These sanctions primarily affect members of the ruling government, military leaders, and individuals connected to the violent repression of opposition groups or violations of human rights. The European Union and the United States have sanctioned individuals who have played key roles in the repression of political opposition, civil society activists, and journalists.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Burundi, particularly in sectors such as government procurement, energy, and security.
  • Review ownership structures of companies operating in Burundi to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) standards.
  • Assess the source of funds and transactions to ensure they are not linked to individuals or entities subject to sanctions, particularly those connected to the government or military.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as government contracts, defense, and infrastructure projects, where corruption and human rights abuses may be more prevalent.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to the ruling party, government officials, or military leaders involved in human rights abuses.
  • Investigate ownership and control structures of entities involved in large or cross-border transactions, particularly those with government or military involvement.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business engagements are not made with individuals or entities subject to sanctions for reasons such as human rights violations, political repression, or links to violence against civilians or opposition groups.
• Monitor for Regulatory Changes
  • Stay updated on political developments in Burundi, particularly changes in the political landscape, government policies, and the human rights situation that could affect the country’s international standing.
  • Monitor for any updates or new sanctions imposed by the EU, U.S., or other international bodies if there is a further deterioration in the political or human rights environment in Burundi.
  • Track updates on Burundi’s regulatory framework regarding financial transparency, anti-money laundering (AML), and counter-terrorism financing (CTF) standards.

Risk Assessment:

High Risk – Burundi presents a high risk in terms of international sanctions. Due to its ongoing political instability, human rights violations, and repression of political opposition, the country remains under targeted sanctions. Businesses engaging with Burundi should exercise heightened due diligence, particularly in sectors linked to the government, military, or politically sensitive areas. Monitoring regulatory changes and political developments is crucial to ensure compliance with international sanctions and to mitigate risks associated with human rights abuses and corruption.

Cabo Verde is not subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country has a stable political and economic environment and is considered a democratic and peaceful nation. Cabo Verde is a member of various international organizations, including the United Nations, the African Union, and the Community of Portuguese Language Countries (CPLP). It generally maintains good relations with other countries and is not involved in significant international disputes that would attract sanctions.

Individuals/Entities under Targeted Sanctions:

Cabo Verde does not have any individuals or entities under targeted sanctions from international regulatory bodies like the United Nations, the European Union, or the United States. The country has a clean record in terms of international sanctions, with no known restrictions placed on its leaders, companies, or other entities. However, as with any country, due diligence should still be applied when engaging in transactions with entities or individuals in Cabo Verde, particularly in sectors that could involve cross-border financial activities.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Cabo Verde, especially in sectors such as government contracts, banking, and international trade.
  • Review ownership structures of entities operating in Cabo Verde to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving higher-risk sectors such as banking or industries that involve significant cross-border transactions.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with connections to government contracts or businesses with state involvement.
  • Investigate the ownership and control structures of entities involved in large, complex, or high-value transactions, especially if these entities have a history of operating in multiple jurisdictions.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities linked to corruption, terrorism, or other illicit activities, even if Cabo Verde itself is not under broad sanctions.
• Monitor for Regulatory Changes
  • Stay updated on political and economic developments in Cabo Verde, particularly any changes in the government or its economic policy that could impact international trade or foreign investment.
  • Monitor any updates in international sanctions regimes or regulatory changes that could affect Cabo Verde’s standing with global financial institutions or international bodies.
  • Track developments related to financial transparency, anti-money laundering (AML), and counter-terrorism financing (CTF) regulations in Cabo Verde.

Risk Assessment:

Low Risk – Cabo Verde presents a low risk in terms of international sanctions. The country enjoys political stability, a solid reputation for democratic governance, and a strong commitment to international cooperation. Businesses engaging with Cabo Verde should still apply standard due diligence procedures, particularly in sectors with a higher potential for illicit activities, but there are no significant concerns related to sanctions or politically exposed persons. Regular monitoring of regulatory changes and global developments is advisable to maintain ongoing compliance.

Cambodia is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. However, the country has faced targeted sanctions over the years due to concerns over human rights violations, political repression, and democratic backsliding. The United States, for instance, has imposed restrictions on certain Cambodian officials and entities associated with the government of Prime Minister Hun Sen, particularly in response to the suppression of opposition and civil society groups. While Cambodia itself is not under broad international sanctions, specific individuals and entities have faced targeted measures.

Individuals/Entities under Targeted Sanctions:

Several individuals and entities in Cambodia, particularly members of the ruling government, military, and business elites, are subject to targeted sanctions. These include asset freezes and travel bans imposed by the United States and the European Union. Sanctions have been levied against government officials and military figures linked to human rights abuses, crackdowns on political opposition, and suppression of free expression. There are also restrictions on companies and individuals involved in corruption, illicit activities, or whose business interests are connected to the military or political leadership.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Cambodia, particularly those involved in sectors like government contracting, real estate, and construction, where corruption risks are higher.
  • Review ownership structures of entities operating in Cambodia to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) standards.
  • Assess the source of funds and transactions to confirm they are not linked to sanctioned individuals, entities, or corruption-linked activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as government contracts, real estate, infrastructure development, and industries linked to military or security interests.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with connections to Cambodia’s ruling elite, military officials, or figures involved in human rights abuses.
  • Investigate the ownership and control structures of entities engaged in large, complex, or cross-border transactions, particularly those with connections to government projects or the military.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure business dealings are not made with individuals or entities linked to corruption, human rights abuses, or the military leadership that are subject to sanctions.
• Monitor for Regulatory Changes
  • Stay updated on political developments in Cambodia, particularly those involving the ruling government’s relationship with opposition groups, civil society, and international organizations.
  • Monitor any updates to sanctions regimes, particularly from the EU or U.S., which may impose further targeted measures if the political and human rights situation deteriorates.
  • Track developments regarding Cambodia’s regulatory environment, especially related to financial transparency, anti-money laundering (AML), and counter-terrorism financing (CTF).

Risk Assessment:

Medium Risk – Cambodia presents a medium risk in terms of international sanctions. While the country is not under comprehensive sanctions, it does face targeted sanctions due to concerns about human rights violations and political repression. Businesses operating in or with Cambodia should exercise due diligence, particularly when dealing with government-linked entities, military sectors, or politically exposed persons. Monitoring of the political environment and changes in sanctions regimes is crucial to mitigate risks associated with corruption and human rights abuses.

Cameroon is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. However, the country has faced international criticism due to its ongoing political and human rights challenges, particularly related to the Anglophone crisis, the repression of political opposition, and concerns over the rule of law. While there are no broad sanctions imposed on Cameroon as a whole, certain individuals associated with human rights abuses or political repression may be subject to targeted measures, particularly from the United States and the European Union.

Individuals/Entities under Targeted Sanctions:

Some individuals from Cameroon, particularly government officials, military leaders, and figures associated with human rights violations or repression of political opposition, may be subject to targeted sanctions. These measures can include travel bans and asset freezes imposed by the United States, the European Union, or other countries. These sanctions are often linked to the ongoing conflict in the Anglophone regions and the crackdown on protests and dissent, as well as concerns regarding corruption and the erosion of democratic principles.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Cameroon, especially in sectors such as defense, government contracting, and natural resources, which may have higher exposure to corruption and human rights risks.
  • Review ownership structures of entities operating in Cameroon to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are not linked to sanctioned individuals, entities, or sectors involved in corruption or human rights violations.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as government contracts, military procurement, and infrastructure projects, where there may be higher risks of corruption, misallocation of resources, or ties to politically exposed persons (PEPs).
  • Scrutinize transactions involving individuals with connections to the Cameroonian government, military, or individuals accused of human rights abuses or political repression.
  • Investigate the ownership and control structures of entities involved in large or complex transactions, particularly those with potential links to government officials or entities associated with the military.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities linked to corruption, human rights violations, or political repression, especially in sensitive sectors like government procurement or military contracts.
• Monitor for Regulatory Changes
  • Stay updated on political developments in Cameroon, particularly in relation to the ongoing conflict in the Anglophone regions and the government's response to political opposition or civil unrest.
  • Monitor any updates to international sanctions or human rights reports that may lead to further targeted sanctions or policy changes affecting individuals or entities within Cameroon.
  • Track regulatory changes within Cameroon, especially those related to anti-money laundering (AML), counter-terrorism financing (CTF), and financial transparency initiatives.

Risk Assessment:

Medium Risk – Cameroon presents a medium risk in terms of international sanctions. While the country is not under comprehensive sanctions, certain individuals and entities are subject to targeted measures due to concerns about political repression, corruption, and human rights violations. Businesses operating in Cameroon should conduct thorough due diligence, especially in sectors linked to government contracts or military activities. Monitoring political developments and sanctions updates is essential to mitigate risks related to human rights abuses and potential exposure to sanctioned individuals.

Canada is not under international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. As a member of several international organizations, including the UN, NATO, and the Commonwealth, Canada adheres to international laws and regulations and is known for its stable political environment, strong rule of law, and commitment to human rights and democracy. However, Canada has, at times, imposed its own sanctions on other countries or individuals, particularly in response to human rights violations, political repression, or acts of terrorism.

Individuals/Entities under Targeted Sanctions:

Canada has its own sanctions list, which includes individuals and entities from other countries who are subject to asset freezes, travel bans, and other restrictions. These sanctions are generally imposed for actions such as supporting terrorism, engaging in human rights violations, or threatening international peace and security. Canada also enforces UN Security Council sanctions and implements sanctions aligned with those of the European Union and the United States. While Canada itself is not under sanctions, it participates in global sanctions regimes against specific countries, individuals, and entities.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Canada, particularly in sectors such as finance, government contracting, and natural resources.
  • Review ownership structures of companies operating in Canada to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any illicit activities or sanctioned entities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as government procurement, financial services, and cross-border trade, where the potential for fraud, money laundering, or other illicit activities may be higher.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to government officials or individuals in sensitive sectors like defense or foreign relations.
  • Investigate ownership and control structures of entities involved in large or cross-border transactions, particularly those with complex ownership chains or international links.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and Canada's own sanctions lists.
  • Ensure that business dealings are not made with individuals or entities that are subject to sanctions for reasons such as terrorism, human rights violations, or corruption.
• Monitor for Regulatory Changes
  • Stay updated on political and economic developments in Canada, particularly changes in government policy or trade relations that could impact business operations.
  • Monitor any updates or new sanctions imposed by Canada, the UN, the U.S., or the EU that could affect international business operations.
  • Track changes in Canada’s financial regulations, including anti-money laundering (AML) and counter-terrorism financing (CTF) laws, which could affect the broader regulatory environment.

Risk Assessment:

Low Risk – Canada presents a low risk in terms of international sanctions. The country enjoys political stability, strong legal frameworks, and a commitment to international cooperation and human rights. Businesses operating in Canada are unlikely to encounter challenges related to international sanctions. However, companies should maintain regular monitoring of sanctions lists and regulatory changes to ensure compliance with evolving global regulations.

The Central African Republic (CAR) is currently subject to international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, and the United States. These sanctions are primarily in response to the country’s ongoing civil conflict, human rights violations, and the presence of armed groups involved in atrocities. The UN Security Council has imposed an arms embargo, targeted asset freezes, and travel bans on individuals and entities involved in the conflict or undermining the peace process. The European Union and the United States have also imposed similar measures against key figures in the CAR government, militia leaders, and those accused of human rights violations.

Individuals/Entities under Targeted Sanctions:

The CAR has several individuals and entities that are subject to targeted sanctions, including asset freezes, travel bans, and restrictions on financial transactions. These sanctions primarily target individuals linked to armed groups, rebel factions, and government officials involved in the conflict, human rights abuses, or the illegal trade in arms and minerals. The UN, EU, and U.S. have sanctioned military leaders, rebel group leaders, and business figures who are believed to be fueling the violence or profiting from the conflict.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in the Central African Republic, particularly in sectors such as natural resources (diamonds, gold, timber) and government contracting, which may have higher exposure to conflict financing and illicit activities.
  • Review ownership structures of entities operating in CAR to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to confirm they are legitimate and not linked to sanctioned entities or individuals involved in the conflict or illegal trade.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as arms trade, mineral extraction, or government contracts, where the risk of involvement in illicit activities is elevated.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with connections to the CAR government, armed groups, or rebel factions.
  • Investigate the ownership and control structures of entities engaged in large or cross-border transactions, especially those with potential links to sanctioned individuals, rebel factions, or militia groups.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities that are linked to the conflict, human rights abuses, or other activities subject to sanctions, such as illegal mining or arms trafficking.
• Monitor for Regulatory Changes
  • Stay updated on political developments in the Central African Republic, particularly regarding peace negotiations, the involvement of armed groups, and the government’s efforts to stabilize the country.
  • Monitor any updates to sanctions regimes, particularly from the UN, EU, and U.S., which may impose further targeted sanctions if the political or security situation deteriorates.
  • Track changes in CAR’s regulatory environment related to financial transparency, anti-money laundering (AML), and counter-terrorism financing (CTF), especially in sectors like mining or natural resource extraction.

Risk Assessment:

High Risk – The Central African Republic presents a high risk in terms of international sanctions. Due to ongoing conflict, human rights abuses, and the involvement of sanctioned entities and individuals, the country is subject to strict targeted sanctions. Businesses operating in or with CAR should apply stringent due diligence, particularly when dealing with sectors linked to the conflict or with entities potentially connected to sanctioned individuals or groups. Regular monitoring of political developments and changes in sanctions is essential to mitigate risks associated with human rights violations, conflict financing, and corruption.

Chad is not currently under comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. However, Chad has faced criticism in the past over issues related to human rights, political repression, and corruption. Despite these concerns, Chad maintains relatively stable diplomatic and economic relations with the international community. The country has been subject to targeted sanctions in the past, particularly under the U.S. and the EU, due to its involvement in regional conflicts, human rights violations, and alleged support for armed groups. While Chad is not under broad sanctions, some individuals and entities may face targeted measures.

Individuals/Entities under Targeted Sanctions:

Some individuals and entities in Chad, particularly those with links to the government or military, have been subject to targeted sanctions due to their involvement in regional conflicts or human rights violations. These sanctions include travel bans, asset freezes, and restrictions on financial transactions. The United States has sanctioned certain officials associated with the Chadian government and its military forces, while the European Union has imposed sanctions on individuals believed to be involved in destabilizing activities in the region or contributing to the repression of political opposition and civil society.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Chad, particularly those involved in sectors such as defense, government contracting, and natural resources.
  • Review ownership structures of entities operating in Chad to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals, entities, or activities related to regional conflicts.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors such as government procurement, military equipment, or mining, where the risk of illicit activities, corruption, and connections to politically exposed persons (PEPs) may be higher.
  • Scrutinize transactions involving individuals with links to the Chadian government, military, or security forces, especially those with known involvement in human rights abuses or political repression.
  • Investigate the ownership and control structures of entities involved in large or cross-border transactions, particularly those with ties to sensitive sectors like defense or natural resources.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities linked to regional conflicts, corruption, or human rights abuses that are subject to sanctions.
• Monitor for Regulatory Changes
  • Stay updated on political and economic developments in Chad, especially with regard to government policy, security concerns, and potential human rights issues.
  • Monitor any updates to sanctions regimes, particularly from the EU and U.S., which may impose further targeted sanctions on individuals or entities involved in destabilizing activities or human rights violations.
  • Track any changes in Chad’s financial regulations or anti-money laundering (AML) frameworks, as well as the country’s overall efforts to improve governance and reduce corruption.

Risk Assessment:

Medium Risk – Chad presents a medium risk in terms of international sanctions. While the country is not subject to comprehensive sanctions, it has faced targeted sanctions in the past due to concerns related to human rights, political repression, and involvement in regional conflicts. Businesses engaging with Chad should exercise due diligence, particularly when dealing with government contracts, defense sectors, or entities linked to military or political leadership. Regular monitoring of political and regulatory changes is essential to mitigate potential risks related to corruption, human rights abuses, or sanctions updates.

The Channel Islands, comprising Jersey, Guernsey, and Sark, are not subject to comprehensive international sanctions from major regulatory bodies such as the United Nations, the European Union, or the United States. However, as Crown Dependencies of the United Kingdom, the Channel Islands follow UK-imposed sanctions, which are in line with EU regulations for EU member states and UN Security Council resolutions. The Channel Islands are regarded as offshore financial centers with strict financial regulation and anti-money laundering (AML) frameworks in place, which aim to maintain the integrity of their financial services industries.

Individuals/Entities under Targeted Sanctions:

Individuals or entities in the Channel Islands may be subject to sanctions if they are involved in activities that are in violation of UK, EU, or UN sanctions. This includes individuals or entities linked to terrorism, corruption, human rights violations, or organized crime. While the Channel Islands themselves are not typically targets of sanctions, businesses or individuals operating within them must comply with sanctions regimes imposed by international bodies. The Channel Islands have been proactive in implementing regulations related to financial transparency and international cooperation on sanctions enforcement, especially in areas like money laundering and tax evasion.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in the Channel Islands, especially in the finance, investment, and real estate sectors.
  • Review ownership structures of entities operating in the Channel Islands to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned entities or individuals involved in illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as financial services, wealth management, and offshore investments, where the potential for illicit activities or money laundering may be higher.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to regimes or countries under international sanctions.
  • Investigate the ownership and control structures of entities involved in large or complex cross-border transactions, especially those with complex ownership chains or potential links to sanctioned individuals or entities.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and the UK’s HM Treasury (for Channel Islands).
  • Ensure that business dealings are not made with individuals or entities linked to corruption, terrorism, or other activities subject to sanctions.
• Monitor for Regulatory Changes
  • Stay updated on changes to the UK's sanctions list, as well as those from the UN or EU, that could affect entities or individuals operating in the Channel Islands.
  • Monitor developments in the Channel Islands’ regulatory framework, especially related to anti-money laundering (AML), counter-terrorism financing (CTF), and tax compliance.
  • Track changes in international relations, particularly with countries under sanctions, as this may affect the Channel Islands' compliance obligations and regulatory landscape.

Risk Assessment:

Low Risk – The Channel Islands present a low risk in terms of international sanctions, given their adherence to the UK's sanctions regimes and robust financial regulation. However, given their role as offshore financial centers, there may be a higher risk of exposure to financial crimes such as money laundering or tax evasion. Businesses operating in the Channel Islands should conduct thorough due diligence, particularly when dealing with complex financial transactions or clients from higher-risk jurisdictions. Regular monitoring of sanctions and regulatory changes is important to ensure ongoing compliance.

Chile is not currently subject to international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. The country enjoys stable political relations with most nations and is an active member of international organizations like the United Nations, the Organization of American States (OAS), and the Pacific Alliance. While Chile maintains strong diplomatic and trade relations globally, it has also been part of multilateral efforts to impose sanctions on other countries when necessary, particularly in response to human rights violations or threats to regional stability.

Individuals/Entities under Targeted Sanctions:

There are no notable individuals or entities in Chile currently subject to targeted international sanctions. Chile's government is committed to upholding international law, democracy, and human rights. However, some individuals or entities from other countries may be sanctioned under Chile's domestic regulations if they engage in activities such as money laundering, terrorism, or corruption. Chile adheres to UN Security Council sanctions and implements relevant measures in accordance with international norms.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Chile, particularly in sectors such as finance, mining, and government contracting.
  • Review the ownership structures of entities operating in Chile to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any illicit or sanctioned entities or individuals.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors such as natural resources (especially mining), government contracts, and large-scale infrastructure projects, where corruption or illicit financial flows may occur.
  • Scrutinize transactions involving politically exposed persons (PEPs) or individuals with links to sensitive government or military sectors.
  • Investigate the ownership and control structures of entities involved in complex or large-scale transactions, particularly those with international ties.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and any other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities linked to terrorism, corruption, or other activities subject to sanctions.
• Monitor for Regulatory Changes
  • Stay updated on political and economic developments in Chile, particularly regarding any changes in government policy, trade relations, or the business environment that may impact regulatory requirements.
  • Monitor updates to sanctions regimes from the UN, U.S., or EU that could affect Chilean businesses or international dealings.
  • Track changes in Chile's domestic regulations related to anti-money laundering (AML), counter-terrorism financing (CTF), and financial transparency, which may affect international business operations.

Risk Assessment:

Low Risk – Chile presents a low risk in terms of international sanctions. The country is a stable democracy with a strong commitment to international relations and human rights. While there are no current sanctions on Chile itself, businesses should remain vigilant by monitoring international sanctions lists and regulatory changes, particularly when engaging in high-risk sectors like mining or government contracting. Regular due diligence is essential to avoid any indirect exposure to sanctioned individuals or entities.

China is not subject to comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States as a whole. However, specific sanctions have been imposed on China by some countries, particularly the U.S. and the EU, targeting certain individuals, companies, or sectors. These sanctions are usually related to concerns over human rights violations (e.g., in Xinjiang and Hong Kong), military activities, and other issues of international concern. Despite these targeted sanctions, China remains an active global player and a permanent member of the United Nations Security Council, where it has the power to veto resolutions.

Individuals/Entities under Targeted Sanctions:

Certain individuals and entities in China are subject to targeted sanctions by the United States, the European Union, and other countries. These sanctions are typically in response to human rights abuses, such as the treatment of ethnic minorities in Xinjiang, actions in Hong Kong, or the military activities in the South China Sea. The U.S. has imposed asset freezes and travel bans on Chinese officials involved in these issues, and certain Chinese companies have been blacklisted from accessing U.S. technology due to national security concerns, particularly in sectors like telecommunications and defense. Additionally, the EU has imposed sanctions on Chinese officials accused of human rights violations.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in China, especially those in sensitive sectors such as technology, defense, and telecommunications.
  • Review the ownership structures of entities operating in China to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any individuals, companies, or entities subject to sanctions.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors such as technology (particularly telecommunications), defense, or entities involved in the surveillance industry, where the potential for sanctions violations or links to human rights abuses may be higher.
  • Scrutinize transactions involving politically exposed persons (PEPs) or individuals with ties to sensitive government sectors, especially those with a potential link to policies or actions that have drawn international sanctions.
  • Investigate the ownership and control structures of entities involved in large or international transactions, particularly those with links to military or government entities.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals, entities, or sectors subject to sanctions, including those related to human rights violations or national security concerns.
• Monitor for Regulatory Changes
  • Stay updated on political and economic developments in China, particularly concerning its foreign policy, human rights situation, or national security measures that may affect business operations.
  • Monitor any updates to sanctions regimes, especially from the U.S. or EU, which may impose new restrictions on individuals, entities, or sectors in China.
  • Track changes in China's domestic regulations related to financial transparency, data privacy, or security laws, as these could have implications for international business.

Risk Assessment:

High Risk – China presents a high risk in terms of international sanctions due to the targeted measures imposed by the U.S., EU, and other countries. These sanctions are linked to human rights issues, national security concerns, and trade disputes. Businesses operating in China or dealing with Chinese entities need to conduct thorough due diligence, especially in high-risk sectors like technology, telecommunications, and defense. Regular monitoring of sanctions lists and regulatory updates is critical to ensure compliance and mitigate exposure to sanctioned individuals or entities.

Colombia is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country has a stable economy and political system and is a key ally of the United States in the region, particularly in efforts to combat drug trafficking and organized crime. While Colombia has faced challenges related to violence and drug-related crimes, it maintains strong international relations. However, certain individuals and entities within Colombia have been subject to targeted sanctions, particularly in relation to drug trafficking and human rights abuses.

Individuals/Entities under Targeted Sanctions:

There are individuals and entities in Colombia that are subject to targeted sanctions, particularly those linked to drug cartels, organized crime, and human rights violations. The U.S. Department of the Treasury (OFAC) has sanctioned Colombian drug traffickers, paramilitary leaders, and criminal organizations under its Office of Foreign Assets Control (OFAC) list. The European Union and other international bodies have also imposed restrictions on individuals involved in criminal activities, particularly those linked to drug production, smuggling, and violent acts. Additionally, certain entities that have been implicated in illegal activities, including armed groups, have been sanctioned.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Colombia, particularly those in industries such as agriculture (e.g., coca cultivation), mining, and government contracting.
  • Review ownership structures of entities operating in Colombia to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned entities or individuals involved in illicit activities like drug trafficking or organized crime.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as mining, oil, or the agricultural sector, where illegal activities or connections to criminal organizations may be more prevalent.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with links to Colombia’s security forces, drug cartels, or paramilitary groups.
  • Investigate the ownership and control structures of entities involved in large or cross-border transactions, especially those with potential ties to sanctioned individuals or organizations involved in drug trafficking or human rights abuses.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals, entities, or sectors involved in drug trafficking, organized crime, or any other activities subject to international sanctions.
• Monitor for Regulatory Changes
  • Stay updated on political and economic developments in Colombia, particularly regarding government efforts to combat organized crime, drug trafficking, and corruption.
  • Monitor updates to sanctions regimes, particularly from the U.S., EU, or other major regulators, which may impose new restrictions on individuals or entities involved in illegal activities.
  • Track changes in Colombia’s financial regulations, anti-money laundering (AML) laws, and counter-terrorism financing (CTF) efforts, especially with regard to sectors vulnerable to illicit activity.

Risk Assessment:

Medium Risk – Colombia presents a medium risk in terms of international sanctions. While the country is not broadly sanctioned, it has targeted sanctions on individuals and entities linked to drug trafficking, organized crime, and human rights violations. Companies operating in Colombia should exercise strong due diligence, particularly in high-risk sectors such as mining, agriculture, and government contracts. Regular screening against sanctions lists and staying informed about political and regulatory changes is essential to mitigate risks associated with criminal organizations or illicit activities.

Comoros is not currently subject to comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. The country has faced various political challenges and instability, but it has generally maintained diplomatic and trade relations with the international community. Comoros is a member of the African Union and the Arab League and is subject to regional and multilateral agreements. While it is not under broad international sanctions, specific restrictions may apply to individuals or entities due to past political instability, corruption, or illegal activities.

Individuals/Entities under Targeted Sanctions:

There are no prominent individuals or entities in Comoros currently under international targeted sanctions. However, Comoros has faced internal political instability, and individuals or entities linked to corruption or unlawful activities may face targeted measures from individual countries. There have been past instances where certain individuals linked to government corruption or illegal activities were subject to asset freezes or travel bans. However, these sanctions are usually not widespread and are limited to those directly involved in illicit actions or violations of international law.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Comoros, especially in sectors such as government contracts, real estate, and natural resources.
  • Review ownership structures of entities operating in Comoros to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any individuals or entities involved in corruption or illegal activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as government procurement, natural resources, and real estate, where the risk of illicit financial flows or corruption may be higher.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with links to the government or military sectors.
  • Investigate the ownership and control structures of entities involved in large or complex transactions, particularly those with potential ties to individuals or entities with a history of corruption or unlawful activities.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities linked to corruption, terrorism, or other activities subject to sanctions.
• Monitor for Regulatory Changes
  • Stay updated on political developments in Comoros, particularly regarding changes in government, reforms, or any developments related to human rights or political instability.
  • Monitor any updates to sanctions regimes that may impact individuals or entities in Comoros due to emerging concerns related to corruption, human rights abuses, or illegal activities.
  • Track changes in Comoros’ financial regulations and anti-money laundering (AML) frameworks, which may affect international business operations or investments in the country.

Risk Assessment:

Medium Risk – Comoros presents a medium risk in terms of international sanctions. While the country is not subject to broad international sanctions, it has experienced political instability and corruption in the past, and certain individuals or entities may be exposed to targeted sanctions. Businesses operating in Comoros should conduct thorough due diligence, particularly when engaging in high-risk sectors like government contracting, real estate, or natural resources. Monitoring of sanctions lists and political developments is essential to mitigate potential risks.

The Republic of the Congo (Congo-Brazzaville) is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. However, like many countries in Africa, the Republic of the Congo has faced challenges related to political instability, corruption, and human rights concerns, which have led to targeted sanctions in the past. The country is a member of the African Union and the Central African Economic and Monetary Community (CEMAC). While it is not broadly sanctioned, some individuals and entities within the country may be subject to targeted restrictions, particularly those linked to corruption or violations of international law.

Individuals/Entities under Targeted Sanctions:

There are no significant, widespread sanctions on the Republic of the Congo itself, but certain individuals or entities have been subject to targeted sanctions. These have generally been imposed by the European Union or the United States, particularly in response to corruption, human rights abuses, or violations of democratic principles. The U.S. and EU have previously imposed travel bans and asset freezes on Congolese officials and businesses linked to corrupt practices, political repression, or illegal activities, such as the embezzlement of state funds.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in the Republic of the Congo, especially those in sectors such as government contracts, natural resources (especially oil), and construction.
  • Review ownership structures of entities operating in the Republic of the Congo to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any individuals or entities involved in corruption, human rights abuses, or unlawful activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors such as oil and gas, mining, or government contracting, where the potential for corruption, illicit financial flows, or links to politically exposed persons (PEPs) is higher.
  • Scrutinize transactions involving politically exposed persons (PEPs) or individuals with ties to the ruling party or military sectors.
  • Investigate the ownership and control structures of entities involved in large or cross-border transactions, particularly those with complex ownership structures or links to individuals or entities with a history of corruption or violations of international law.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals, entities, or sectors linked to corruption, human rights abuses, or other activities subject to international sanctions.
• Monitor for Regulatory Changes
  • Stay updated on political and economic developments in the Republic of the Congo, particularly regarding changes in government, political reforms, or developments related to human rights or corruption.
  • Monitor updates to sanctions regimes, particularly from the U.S., EU, or other relevant regulators, which may impose new restrictions on individuals or entities in the Republic of the Congo.
  • Track changes in the country’s financial regulations, anti-money laundering (AML) laws, and counter-terrorism financing (CTF) measures, which may impact international business operations.

Risk Assessment:

Medium Risk – The Republic of the Congo presents a medium risk in terms of international sanctions. While the country is not subject to broad sanctions, it has been affected by targeted measures, particularly in response to corruption and human rights concerns. Businesses operating in Congo should conduct thorough due diligence, particularly in high-risk sectors like natural resources, government contracting, and real estate, where corruption and illicit activities may be more prevalent. Monitoring sanctions lists and political developments in the country is crucial to mitigate risks.

Costa Rica is not currently subject to international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country is known for its stable democracy, peaceful foreign policy, and strong rule of law. It is an active member of international organizations, including the United Nations, the Organization of American States (OAS), and the Central American Integration System (SICA). Costa Rica enjoys good diplomatic relations globally and is considered a safe investment destination in the region. However, it is essential to be aware of any potential issues that could arise from global financial or environmental concerns that may impact specific sectors.

Individuals/Entities under Targeted Sanctions:

There are no known individuals or entities in Costa Rica currently subject to targeted international sanctions. Costa Rica's government is committed to international law, democracy, and human rights. The country generally does not face sanctions and has not been involved in activities that would trigger such measures. However, as with all countries, certain individuals or entities may be targeted by sanctions in the event of violations of international law or involvement in illicit activities, though this has not been a significant issue for Costa Rica in recent years.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Costa Rica, particularly those in sectors such as finance, real estate, and technology.
  • Review ownership structures of entities operating in Costa Rica to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any illicit entities or activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence when dealing with sectors involving high-value transactions, such as real estate or government contracts, where the potential for money laundering or corruption may arise.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to government or financial sectors.
  • Investigate the ownership and control structures of entities involved in large-scale transactions or those with cross-border implications, especially if they are connected to individuals or entities with potential links to corruption or illegal activities.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities linked to activities subject to sanctions, such as terrorism, corruption, or human rights abuses.
• Monitor for Regulatory Changes
  • Stay updated on political and economic developments in Costa Rica, particularly regarding any changes in government policy, economic stability, or environmental regulations.
  • Monitor any updates to sanctions regimes that may indirectly impact Costa Rican entities, particularly with regard to sectors such as finance, trade, or international business.
  • Track changes in Costa Rica’s financial and regulatory landscape, including updates to anti-money laundering (AML) laws, environmental regulations, and other compliance-related measures.

Risk Assessment:

Low Risk – Costa Rica presents a low risk in terms of international sanctions. The country maintains a reputation for stability, democracy, and commitment to international law. While Costa Rica is not subject to comprehensive sanctions and there are no targeted sanctions on individuals or entities, businesses should always ensure proper due diligence, especially in sectors like real estate and government contracting where the risk of illicit financial activity may arise. Regular monitoring of sanctions lists and regulatory changes is important to remain compliant and avoid exposure to risks.

Côte d'Ivoire is not currently subject to comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. The country has made significant strides since its civil conflict in the early 2000s and the post-election crisis in 2010-2011. Following these events, Côte d'Ivoire underwent a process of political and economic recovery, which has been largely supported by the international community. Although there have been past sanctions, particularly during the civil conflict, Côte d'Ivoire is now considered relatively stable and has been removed from most sanction lists. However, some targeted sanctions remain on individuals and entities linked to political instability and criminal activities.

Individuals/Entities under Targeted Sanctions:

Several individuals and entities in Côte d'Ivoire have been subject to targeted sanctions, particularly in the context of the post-election crisis and the civil conflict. The United Nations, European Union, and United States have imposed sanctions on specific individuals and entities connected to the Ivorian government, military, and opposition leaders involved in human rights violations, illegal activities, or undermining the peace process. These sanctions typically include asset freezes, travel bans, and restrictions on business dealings. As of now, the country as a whole is no longer under comprehensive sanctions, but some figures may still face restrictions due to their involvement in past unrest or illicit activities.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Côte d'Ivoire, particularly in sectors such as government contracts, agriculture, and natural resources.
  • Review ownership structures of entities operating in Côte d'Ivoire to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any sanctioned individuals or entities involved in past political instability or criminal activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors such as government procurement, natural resources (particularly cocoa and oil), and real estate, where corruption or links to politically exposed persons (PEPs) may be more prevalent.
  • Scrutinize transactions involving individuals with ties to the Ivorian government, military, or past political leaders, particularly those with links to the civil conflict or human rights abuses.
  • Investigate the ownership and control structures of entities involved in large or cross-border transactions, particularly those with complex ownership or connections to sanctioned individuals or organizations.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities that remain subject to international sanctions, especially those linked to human rights violations, corruption, or criminal activities from past conflicts.
• Monitor for Regulatory Changes
  • Stay updated on political and economic developments in Côte d'Ivoire, particularly regarding changes in government leadership, the political climate, or potential risks of instability that could lead to new sanctions or regulatory changes.
  • Monitor updates to sanctions regimes, particularly from the U.S., EU, or the UN, which may impose new restrictions on individuals, entities, or sectors in Côte d'Ivoire due to concerns related to corruption, human rights violations, or political instability.
  • Track changes in Côte d'Ivoire’s financial regulations, anti-money laundering (AML) frameworks, and counter-terrorism financing (CTF) measures to ensure compliance with international standards.

Risk Assessment:

Medium Risk – Côte d'Ivoire presents a medium risk in terms of international sanctions. While the country is not currently subject to broad sanctions, certain individuals and entities remain under targeted sanctions due to past political instability and human rights concerns. Businesses operating in Côte d'Ivoire should conduct thorough due diligence, particularly in high-risk sectors such as government contracting, natural resources, and real estate. Regular monitoring of sanctions lists and political developments is important to mitigate any risks associated with individuals or entities linked to past conflicts or illicit activities.

Croatia is not subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. Croatia is a member of the European Union (EU), NATO, and the United Nations, and it adheres to the international rules and regulations established by these organizations. Since joining the EU in 2013, Croatia has been in good standing with major international governance frameworks. It is a stable, democratic country with strong economic ties to the EU and the global market, and it is not currently a source of concern for international sanctions.

Individuals/Entities under Targeted Sanctions:

There are no prominent individuals or entities in Croatia currently under targeted sanctions. Croatia has generally complied with international laws and EU regulations, and as an EU member state, it participates in the EU’s common foreign and security policy. While Croatia itself is not subject to sanctions, any Croatian individuals or entities involved in violations of international law or engaged in illicit activities may be subject to sanctions imposed by the EU, the United Nations, or other authorities. For example, sanctions may apply to individuals or entities involved in corruption or terrorism, though this has not been a significant concern for Croatia in recent years.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Croatia, particularly in sectors such as finance, real estate, and manufacturing.
  • Review ownership structures of entities operating in Croatia to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors involving government contracts, public tenders, or large infrastructure projects, where the risk of corruption or illicit activity may be higher.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to the government, business, or military sectors.
  • Investigate the ownership and control structures of entities involved in large-scale or cross-border transactions, particularly if they involve parties with complex ownership or potential links to corruption.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, corruption, or terrorism.
• Monitor for Regulatory Changes
  • Stay informed about any updates to EU regulations or international policies that may affect business operations in Croatia, particularly those related to anti-money laundering (AML) or counter-terrorism financing (CTF).
  • Monitor political developments in Croatia, especially in relation to changes in government policy, economic reforms, or potential regulatory shifts.
  • Track any changes to the EU’s sanctions regimes, particularly with regard to countries or entities in the Balkans, as well as updates to Croatia's own financial regulations and business compliance measures.

Risk Assessment:

Low Risk – Croatia presents a low risk in terms of international sanctions. As an EU member state with a stable political and economic environment, it is not subject to any significant international sanctions. Businesses operating in Croatia should follow standard due diligence procedures, particularly in sectors with higher risks of corruption or illicit activity. However, due diligence remains important to ensure compliance with global financial regulations and to screen against sanctions lists, especially when dealing with international partners or high-risk transactions.

Cuba is subject to comprehensive international sanctions, primarily imposed by the United States and, to a lesser extent, the European Union. The U.S. maintains a long-standing embargo against Cuba, imposing broad restrictions on trade, travel, and financial transactions. The European Union, while not imposing an embargo, has targeted sanctions related to human rights abuses and restrictions on certain Cuban officials and entities. As a result, Cuba remains under significant international scrutiny, particularly from the U.S., due to its political environment and the actions of the Cuban government, which has been linked to human rights violations and other controversial activities.

Individuals/Entities under Targeted Sanctions:

Cuba has several entities and individuals under targeted sanctions, primarily imposed by the United States. These sanctions focus on Cuban government officials, military leaders, and entities linked to activities such as the repression of political dissent, violations of human rights, and involvement in activities undermining democratic processes. The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) maintains a list of Cuban individuals and entities subject to financial restrictions. The European Union also imposes sanctions on certain Cuban officials but generally takes a less restrictive stance compared to the U.S.

Recommendations:

• Standard Due Diligence
  • Verify the identities of all business partners, customers, or entities that have links to Cuba, particularly those operating in sectors like tourism, energy, or finance.
  • Conduct a thorough review of the ownership structures of entities operating in or linked to Cuba, especially those potentially involved in sanctioned activities or controlled by Cuban government interests.
  • Assess the source of funds and transactions involving Cuban parties to ensure they are legitimate and not connected to any prohibited activities or individuals under sanction.
• Enhanced Due Diligence
  • For high-value transactions or business engagements with Cuban government entities, military, or any state-owned enterprises, apply enhanced due diligence to mitigate the risks of illicit activity or sanctions violations.
  • Scrutinize transactions involving politically exposed persons (PEPs) or individuals with ties to Cuba’s government or military.
  • Review the ownership structures of any Cuban entities involved in large-scale or cross-border transactions to ensure no links to sanctioned individuals or entities.
• Screen Against Sanctions Lists
  • Regularly screen clients, business partners, and transactions against global sanctions lists, particularly the U.S. OFAC lists, EU sanctions lists, and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to the Cuban government or other sanctioned sectors such as defense or intelligence.
• Monitor for Regulatory Changes
  • Stay informed about changes to U.S. sanctions regulations concerning Cuba, as these are subject to frequent updates, particularly in response to political shifts.
  • Regularly check for updates to European Union sanctions on Cuba, especially concerning individuals or entities under scrutiny for human rights violations or repression.
  • Track changes in international policies or regulations related to Cuba, including potential easing or tightening of sanctions, which could impact business operations or legal compliance.

Risk Assessment:

High Risk – Cuba presents a high-risk environment in terms of international sanctions. The comprehensive U.S. embargo and the targeted EU sanctions make it a complex landscape for business operations. Entities dealing with Cuba must be diligent in compliance efforts, particularly when engaging in financial transactions or cross-border trade that may involve sanctioned individuals or entities. Continuous monitoring of both U.S. and EU regulations is crucial for mitigating exposure to legal and financial risks.

Cyprus is not subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. Cyprus is a member of the European Union (EU), the United Nations, and other international organizations. As an EU member state, Cyprus adheres to EU regulations and participates in the EU's common foreign and security policy. While Cyprus has faced challenges due to its geographical proximity to conflict zones, it is generally considered a stable, democratic country with strong economic ties to both the EU and the global market. Cyprus is not currently a significant source of concern for international sanctions, though it follows EU sanctions regimes in response to issues such as the situation in Ukraine, human rights violations, or other global issues.

Individuals/Entities under Targeted Sanctions:

There are no prominent individuals or entities in Cyprus currently subject to targeted sanctions by major international bodies like the EU or the United Nations. However, Cyprus, as part of the EU, enforces EU sanctions on individuals or entities linked to activities such as terrorism, human rights violations, or the proliferation of weapons of mass destruction. Cyprus may also apply sanctions in alignment with the UN Security Council resolutions. Businesses or individuals in Cyprus found to be involved in such activities could face sanctions, but this has not been a significant concern in recent years.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers in Cyprus, particularly in sectors such as finance, real estate, and energy, where the risk of illicit activity may be higher.
  • Review the ownership structures of entities operating in Cyprus to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure legitimacy and confirm they are not linked to sanctioned individuals or entities.
• Enhanced Due Diligence
  • For high-value transactions or dealings with politically exposed persons (PEPs) or those linked to the Cypriot government, apply enhanced due diligence procedures.
  • Scrutinize any transactions involving sensitive sectors, such as banking, shipping, or defense, where there may be higher risks of corruption, money laundering, or financing of terrorism.
  • Investigate the ownership and control structures of entities involved in large-scale transactions, particularly if they involve complex ownership or offshore structures that could raise concerns.
• Screen Against Sanctions Lists
  • Regularly screen clients, transactions, and business partners against global sanctions lists, including those from the EU, the UN, and other relevant authorities such as the U.S. Office of Foreign Assets Control (OFAC).
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, corruption, or terrorism, in line with international sanctions regimes.
• Monitor for Regulatory Changes
  • Stay informed about updates to EU sanctions regulations, particularly those affecting business activities in Cyprus, especially regarding sanctions related to Russia, Iran, or other regions of concern.
  • Monitor political developments in Cyprus and any changes in government policy, which may impact the country’s stance on international sanctions or local regulations.
  • Track changes in the EU’s broader sanctions regimes, particularly as they relate to Cyprus’s obligations and role in European foreign policy.

Risk Assessment:

Low Risk – Cyprus presents a low risk in terms of international sanctions. As an EU member state, it adheres to European and international rules and regulations. There are no significant sanctions concerns related to Cyprus itself, but businesses should remain aware of the EU’s broader sanctions regimes. Due diligence is recommended, particularly in sectors with higher risks of illicit activities, such as finance, real estate, and shipping. However, Cyprus remains a relatively stable environment for international business.

Czech Republic is not subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The Czech Republic is a member of the European Union (EU), NATO, and the United Nations, and it adheres to the international regulations and policies set by these organizations. As an EU member, the Czech Republic follows EU policies, including sanctions imposed by the EU in response to global issues such as human rights violations, terrorism, or the destabilization of regions. The Czech Republic itself is not a source of concern for international sanctions and is considered a stable, democratic country with a well-functioning economy and strong ties to both the EU and the global market.

Individuals/Entities under Targeted Sanctions:

There are no prominent individuals or entities in the Czech Republic currently subject to targeted sanctions by major international bodies. However, as an EU member state, the Czech Republic enforces EU sanctions on individuals or entities connected to activities such as terrorism, human rights abuses, or the proliferation of weapons of mass destruction. The Czech Republic may also apply sanctions based on United Nations Security Council resolutions. While there have been occasional cases involving Czech entities or individuals violating international laws, these have not been major concerns in recent years.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in the Czech Republic, particularly in high-risk sectors such as finance, defense, and energy.
  • Review ownership structures of entities operating in the Czech Republic to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any sanctioned individuals or illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions, particularly those involving government contracts, public tenders, or sensitive sectors like defense, banking, and real estate.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to the Czech government, military, or business sectors.
  • Investigate the ownership and control structures of entities involved in large-scale or cross-border transactions, especially when the ownership structure is complex or involves offshore entities.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, and U.S. Department of Treasury (OFAC).
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, or corruption, as defined by international sanctions.
• Monitor for Regulatory Changes
  • Stay informed about any updates to EU regulations or international policies that may affect business operations in the Czech Republic, particularly regarding anti-money laundering (AML) and counter-terrorism financing (CTF).
  • Monitor political developments in the Czech Republic, especially in relation to any changes in government policy, economic reforms, or potential regulatory shifts.
  • Track any updates to the EU’s sanctions regimes, particularly those related to countries or entities of concern within the EU's foreign policy context, as well as any changes to the Czech Republic's financial regulations or business compliance measures.

Risk Assessment:

Low Risk – The Czech Republic presents a low risk in terms of international sanctions. As a stable EU member state, it adheres to EU and international regulations and has no significant history of being directly subject to sanctions. Businesses operating in the Czech Republic should follow standard due diligence procedures, especially when engaging in sectors where corruption or illicit activity may be more common. Nonetheless, businesses should remain vigilant and monitor any relevant changes in international sanctions or regulations that could impact operations in the Czech Republic.

Denmark is not subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a member of the European Union, NATO, and the United Nations, Denmark adheres to the international sanctions regimes established by these organizations. While Denmark itself is not under sanctions, it complies with EU sanctions targeting individuals, entities, or countries involved in human rights violations, terrorism, and other illegal activities. Denmark is a stable, democratic country with a strong economy and is not considered a source of concern for international sanctions.

Individuals/Entities under Targeted Sanctions:

There are no prominent individuals or entities in Denmark currently subject to international targeted sanctions. However, Denmark enforces EU sanctions, which may include restrictions on individuals or entities associated with activities such as corruption, terrorism, or human rights abuses. Danish entities could also be involved in the enforcement of international sanctions, especially in sectors like finance, defense, or technology.

Recommendations:

• Standard Due Diligence
  • Verify the identities of all business partners, clients, and entities operating in Denmark, particularly in high-risk sectors like finance, shipping, and energy.
  • Review the ownership structures of companies based in Denmark to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not connected to any sanctioned individuals or illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings involving sensitive sectors such as government contracts, defense, or technology, where risks of corruption or illicit activity may be higher.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to the Danish government or military sectors.
  • Investigate the ownership and control structures of entities engaged in large-scale or cross-border transactions, especially when they involve complex ownership or offshore entities.
• Screen Against Sanctions Lists
  • Regularly screen clients, business partners, and transactions against global sanctions lists, including those maintained by the EU, UN, and the U.S. Department of Treasury (OFAC).
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, or corruption, in compliance with international sanctions regimes.
• Monitor for Regulatory Changes
  • Stay informed about updates to EU sanctions regulations, especially those that could affect business operations in Denmark or related to politically sensitive regions or entities.
  • Monitor political developments in Denmark that may lead to shifts in government policy, economic reforms, or changes in regulations affecting sanctions or compliance measures.
  • Track changes to the EU’s sanctions regimes, as Denmark aligns with EU foreign policy and sanctions regulations.

Risk Assessment:

Low Risk – Denmark presents a low risk in terms of international sanctions. It is a stable EU member state with a strong regulatory environment. While Denmark adheres to international sanctions, it does not face significant risks of being directly impacted by sanctions itself. Businesses should follow standard due diligence procedures, particularly in sectors with higher risks of illicit activities.

Djibouti is not subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. Djibouti is a member of the United Nations and the African Union, and it adheres to international regulations and policies set by these organizations. Djibouti is considered a stable country strategically located at the crossroads of international trade routes, particularly in the Horn of Africa. Although Djibouti itself is not under sanctions, it plays a significant role in regional stability and international trade. However, businesses engaging with Djibouti must be aware of potential risks related to regional conflicts or links to countries under sanctions.

Individuals/Entities under Targeted Sanctions:

There are no prominent individuals or entities in Djibouti currently subject to targeted international sanctions. However, Djibouti may be indirectly affected by sanctions imposed on other countries in the region or by global entities for violations of international laws or human rights. As Djibouti is located in a geopolitically sensitive area near countries such as Somalia and Eritrea, any sanctions imposed on its neighboring countries may affect trade, security, and business operations in Djibouti. Additionally, international sanctions could apply to Djibouti-based entities or individuals that engage in activities connected to illicit trade, terrorism, or human rights abuses, though these have not been major concerns in recent years.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and clients operating in Djibouti, particularly in sectors such as shipping, logistics, and construction, where the risk of corruption or illicit activities could be higher.
  • Review ownership structures of companies operating in Djibouti to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any sanctioned individuals or illegal activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or engagements with sectors involving critical infrastructure, defense, or government contracts, where the risk of corruption or illicit activity may be higher.
  • Scrutinize transactions involving politically exposed persons (PEPs) or individuals with close ties to the government or military sectors in Djibouti.
  • Investigate the ownership and control structures of entities involved in cross-border transactions, especially when dealing with offshore entities or complex ownership structures that may be linked to regional risks.
• Screen Against Sanctions Lists
  • Regularly screen clients, transactions, and business partners against global sanctions lists, including those maintained by the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, or human rights abuses.
• Monitor for Regulatory Changes
  • Stay informed about updates to sanctions regulations, particularly those affecting Djibouti’s neighboring countries or the wider Horn of Africa region, which could impact business operations in Djibouti.
  • Monitor political developments in Djibouti, especially in relation to any changes in government policy or regional instability that could affect international relations and business operations.
  • Track changes to the broader sanctions regimes, particularly those related to countries in the Horn of Africa, which may have an impact on Djibouti’s trade or security dynamics.

Risk Assessment:

Medium Risk – Djibouti presents a medium risk in terms of international sanctions. While it is not subject to direct international sanctions, its strategic location and proximity to countries facing sanctions or involved in conflict could present indirect risks. Businesses engaging with Djibouti should be diligent in conducting standard and enhanced due diligence, especially in sectors with higher risks of illicit activities or corruption. Continuous monitoring of regional developments and sanctions updates is essential to mitigate potential risks.

Dominica is not subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. Dominica is an independent Caribbean nation and a member of the United Nations, the Caribbean Community (CARICOM), and other regional and international organizations. It maintains a stable political environment and adheres to the international regulations established by these bodies. Although Dominica itself is not under sanctions, it is important to note that businesses operating there should be mindful of global financial regulations and international sanctions that may apply to other regions or individuals, particularly in sectors like offshore finance.

Individuals/Entities under Targeted Sanctions:

There are no prominent individuals or entities in Dominica currently subject to targeted international sanctions. However, as part of its commitment to international standards, Dominica enforces sanctions consistent with those imposed by international organizations such as the United Nations and the United States, especially regarding issues like human rights violations, terrorism, and the proliferation of weapons of mass destruction. Given Dominica's offshore financial services sector, businesses must be cautious of individuals or entities from other jurisdictions that could be subject to sanctions but operate within the country.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and clients in Dominica, particularly in sectors such as offshore finance, real estate, and tourism, where there could be higher risks of money laundering or illicit financial activities.
  • Review the ownership structures of entities operating in Dominica to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with individuals or companies involved in the offshore finance sector or with ties to high-risk regions, where there may be concerns about money laundering, tax evasion, or financial crimes.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to countries under sanctions or those involved in sectors with higher risks of corruption.
  • Investigate the ownership and control structures of entities involved in cross-border transactions, particularly when they involve complex ownership structures or offshore entities with limited transparency.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, or human rights abuses, in accordance with international sanctions regimes.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Caribbean nations, offshore financial activities, and regions with heightened risks of illicit activities.
  • Monitor political developments in Dominica, particularly changes in government policy, regulatory adjustments, or any involvement in regional or international disputes that could affect international relations or business activities.
  • Track any updates to the broader international sanctions regimes, especially those that could affect the financial services sector or global trade relationships, which may impact operations in Dominica.

Risk Assessment:

Medium Risk – Dominica presents a medium risk in terms of international sanctions. While it is not directly under sanctions, its offshore finance sector and geographic location in the Caribbean may expose businesses to risks related to illicit financial activities or sanctions violations. Due diligence should be carefully conducted, particularly when engaging in high-value transactions or dealing with offshore entities. Monitoring for regulatory changes, especially in relation to the global financial system, is essential to mitigate potential risks.

The Dominican Republic is not subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a sovereign nation in the Caribbean, the Dominican Republic adheres to international laws and regulations through its membership in organizations such as the United Nations and the Organization of American States (OAS). While the country is not under any direct sanctions, businesses operating within the Dominican Republic must remain aware of potential risks related to regional instability or sanctions imposed on entities or individuals from other nations in the Caribbean or Latin America.

Individuals/Entities under Targeted Sanctions:

There are no prominent individuals or entities in the Dominican Republic currently subject to international targeted sanctions. However, the country enforces sanctions consistent with those imposed by international bodies such as the United Nations and the United States, especially in relation to issues like drug trafficking, human rights violations, and corruption. As the Dominican Republic is part of the broader Caribbean region, entities or individuals operating within or outside the country may face sanctions if linked to activities such as money laundering, terrorism, or organized crime, which could indirectly affect the country.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities based in the Dominican Republic, especially in sectors such as real estate, tourism, and offshore financial services, where the risk of illicit activity may be higher.
  • Review ownership structures of companies operating in the Dominican Republic to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any sanctioned individuals or illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions, particularly those involving government contracts, large-scale construction projects, or industries with higher risks of corruption.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to the Dominican government or influential sectors like business or the military.
  • Investigate the ownership and control structures of entities engaged in cross-border transactions, particularly those with complex ownership or potential links to illicit financial activities.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those maintained by the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, drug trafficking, or human rights abuses, as outlined in international sanctions frameworks.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, especially those affecting the Caribbean region, as the Dominican Republic may be indirectly impacted by sanctions targeting neighboring countries.
  • Monitor political developments in the Dominican Republic, particularly changes in government policy, economic reforms, or any actions that could affect international relations or business operations.
  • Track any updates to broader international sanctions regimes, particularly those targeting the Caribbean region, which may impact business dealings in the Dominican Republic.

Risk Assessment:

Medium Risk – The Dominican Republic presents a medium risk in terms of international sanctions. While not directly subject to sanctions, the country's involvement in the Caribbean region, with its proximity to other high-risk nations, means there are indirect risks. Businesses should conduct thorough due diligence, especially when dealing with sectors such as finance, real estate, and government contracts, where the risk of corruption or illicit activities may be elevated. Continuous monitoring of sanctions lists and regulatory changes is essential to ensure compliance and mitigate risks.

The Democratic Republic of the Congo (DR Congo) is subject to international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, and the United States. These sanctions have been imposed due to ongoing concerns related to human rights violations, conflict financing, corruption, and the instability in the region. The UN has maintained a comprehensive sanctions regime against DR Congo for years, including travel bans and asset freezes against individuals and entities associated with armed groups or those involved in the illegal exploitation of natural resources. The European Union and the United States have similarly imposed targeted sanctions on key individuals and entities linked to the ongoing conflict in the eastern part of the country.

Individuals/Entities under Targeted Sanctions:

There are numerous individuals and entities in DR Congo currently subject to targeted international sanctions. These sanctions primarily focus on those individuals or groups involved in armed conflict, human rights abuses, or the illegal trade of minerals and wildlife. Key individuals from political, military, and militia backgrounds, along with entities operating in the mining, arms trade, and illegal logging sectors, face asset freezes, travel bans, and other financial sanctions. These measures are part of broader international efforts to promote peace and stability in the region.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities based in DR Congo, particularly those in high-risk sectors such as mining, defense, and natural resources, where there is a higher likelihood of exposure to conflict-related activities or corruption.
  • Review ownership structures of companies operating in DR Congo to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or activities associated with illegal resource extraction or militia groups.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or those involving sectors linked to natural resources, such as mining, where the risk of illicit financial flows and corruption is significant.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to the government, military, or militia groups involved in the ongoing conflict.
  • Investigate the ownership and control structures of entities involved in cross-border transactions, particularly those dealing with commodities or resources that are at risk of being illicitly sourced or exploited.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to conflict financing, human rights abuses, or illegal natural resource extraction, as outlined in the international sanctions frameworks.
• Monitor for Regulatory Changes
  • Stay informed about updates to international sanctions regulations, particularly those affecting DR Congo, especially as new individuals or entities may be added to the sanctions list based on ongoing conflict or human rights violations.
  • Monitor political developments in DR Congo, particularly related to peace processes, governance reforms, or any changes that could lead to shifts in international sanctions or regulatory measures.
  • Track any updates to broader international sanctions regimes, particularly those affecting the Great Lakes region or Central Africa, which could have an impact on DR Congo's business and trade relationships.

Risk Assessment:

High Risk – DR Congo presents a high risk in terms of international sanctions. The country is subject to significant sanctions due to its ongoing internal conflicts, human rights abuses, and the involvement of various entities in illegal activities. Businesses operating in DR Congo must conduct extensive due diligence, particularly in high-risk sectors like mining, natural resources, and defense. It is crucial to regularly monitor sanctions lists and stay updated on regulatory changes to ensure compliance with international sanctions and mitigate exposure to illicit activities.

Ecuador is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. Ecuador maintains a stable political environment and is a member of several international organizations, including the United Nations and the Organization of American States (OAS). The country generally adheres to international standards, and its foreign policy aligns with those of regional organizations. While Ecuador is not directly under sanctions, businesses should be aware that sanctions could be imposed in the future in response to political or economic changes, especially if the country engages in activities contrary to international laws, such as human rights violations or illicit trade.

Individuals/Entities under Targeted Sanctions:

Currently, there are no prominent individuals or entities in Ecuador that are subject to targeted international sanctions. However, Ecuador does comply with international sanctions imposed by global bodies such as the United Nations and the U.S. Department of Treasury (OFAC) on individuals or entities involved in activities such as drug trafficking, terrorism, or corruption. While Ecuador itself is not under sanctions, businesses must remain vigilant about potential risks from international sanctions that may apply to Ecuadorian individuals or entities indirectly involved in illicit activities.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Ecuador, especially in sectors such as mining, finance, and energy, where the risk of corruption or illicit activities might be higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors linked to government contracts, natural resources, or sensitive industries where there may be higher risks of corruption or illegal activities.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to the Ecuadorian government or military.
  • Investigate the ownership and control structures of entities engaged in large-scale or cross-border transactions, especially when dealing with offshore entities or complex ownership structures that may be associated with higher risks.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, or corruption, as per the sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Latin American countries, as changes to Ecuador’s political landscape could lead to sanctions or new financial regulations.
  • Monitor political developments in Ecuador, particularly any shifts in government policy, economic reforms, or potential changes to international relations that could affect the country’s sanctions status.
  • Track changes to the broader international sanctions regimes, especially those targeting Latin American countries or regions involved in transnational issues such as drug trafficking or corruption.

Risk Assessment:

Low Risk – Ecuador presents a low risk in terms of international sanctions. The country is not currently subject to comprehensive sanctions, and its political and economic environment remains relatively stable. However, businesses operating in Ecuador should conduct standard due diligence procedures, particularly in sectors where risks of corruption or illicit activities may be higher. Continuous monitoring of political developments and regulatory changes is advisable to ensure compliance with any future sanctions or regulatory adjustments.

Egypt is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country maintains a relatively stable political environment and is an active member of various international organizations, including the United Nations and the African Union. While Egypt itself is not under broad sanctions, there are targeted measures imposed on specific individuals and entities, particularly those involved in human rights abuses, corruption, or terrorism. Businesses should remain aware of the potential risks arising from these targeted sanctions, especially with regard to individuals or entities that may be indirectly linked to illicit activities.

Individuals/Entities under Targeted Sanctions:

• There are no prominent individuals or entities in Egypt currently subject to broad international sanctions.
• However, Egypt complies with international sanctions imposed by global bodies such as the U.S. Department of Treasury (OFAC) and the European Union, targeting individuals and entities linked to terrorism, corruption, or human rights violations.
• Businesses should be vigilant about the potential risks of indirect exposure to individuals or entities involved in these activities, as they may face sanctions or restrictions from international authorities.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Egypt, particularly in sectors such as government contracts, defense, and security services where the risk of corruption or illicit activities may be higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings in sectors linked to sensitive industries like government contracts, natural resources, and defense.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to the Egyptian government, military, or businesses with potential connections to corruption or human rights abuses.
  • Investigate the ownership and control structures of entities involved in large-scale or cross-border transactions, especially when dealing with offshore entities or complex ownership structures that may be associated with higher risks.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, corruption, or human rights violations, in accordance with sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Egypt or the broader Middle East and North Africa region.
  • Monitor political and economic developments in Egypt, particularly any changes in government policies, economic reforms, or international relations that could impact the country’s sanctions status.
  • Track broader changes to international sanctions regimes, especially those targeting the Middle East or regions involved in issues such as terrorism or human rights violations.

Risk Assessment:

Medium Risk – Egypt presents a medium risk in terms of international sanctions. While the country itself is not under broad sanctions, certain individuals and entities are subject to targeted measures due to links to terrorism, human rights abuses, or corruption. Businesses operating in Egypt should conduct thorough due diligence, remain vigilant to potential indirect exposure to illicit activities, and continuously monitor political and regulatory developments to ensure compliance with future sanctions or regulatory changes.

El Salvador is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country maintains a relatively stable political environment and is a member of international organizations like the United Nations and the Organization of American States (OAS). While El Salvador is not directly under sanctions, targeted measures have been applied to individuals and entities involved in organized crime, corruption, and human rights violations. Businesses should remain aware of potential risks, as sanctions may be imposed in the future if the country engages in activities contrary to international law.

Individuals/Entities under Targeted Sanctions:

• No prominent individuals or entities in El Salvador are currently subject to broad international sanctions.
• However, El Salvador complies with international sanctions, including those from the U.S. Department of Treasury (OFAC) and the United Nations, targeting individuals or groups involved in activities such as drug trafficking, corruption, or organized crime.
• Businesses should remain vigilant to the potential risks of indirect exposure to sanctioned individuals or entities involved in illicit activities.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in El Salvador, especially in sectors with higher corruption or illicit activity risks (e.g., construction, finance, public contracts).
  • Review ownership structures to identify any connections to politically exposed persons (PEPs) or individuals with a history of criminal or corrupt activities.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions, particularly those involving government contracts, natural resources, or sensitive industries linked to corruption or illegal activities.
  • Scrutinize transactions involving PEPs or individuals with ties to the Salvadoran government, military, or businesses with potential associations to corruption.
  • Investigate complex ownership and control structures of entities involved in large-scale or cross-border transactions, especially when dealing with offshore entities that may be associated with higher risks.
• Screen Against Sanctions Lists
  • Regularly screen clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, drug trafficking, corruption, or terrorism, in accordance with sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Latin American countries or changes in U.S. policies.
  • Monitor political and economic developments in El Salvador, especially any shifts in government policies or reforms that could influence the country’s sanctions status.
  • Track broader changes in international sanctions regimes, particularly those targeting Latin American countries or regions involved in transnational issues such as drug trafficking or organized crime.

Risk Assessment:

Medium Risk – El Salvador presents a medium risk in terms of international sanctions. While the country is not under broad sanctions, targeted measures are in place for individuals and entities involved in organized crime and corruption. Businesses operating in El Salvador should conduct thorough due diligence, remain cautious of potential indirect exposure to illicit activities, and continuously monitor political and regulatory developments to ensure compliance with future sanctions or regulatory changes.

Equatorial Guinea is currently subject to international sanctions imposed by major regulatory bodies such as the United States and the European Union. These sanctions primarily target individuals and entities linked to corruption, human rights abuses, and the suppression of democratic processes. The U.S. Department of Treasury (OFAC) and the European Union have imposed targeted measures, including asset freezes and travel bans, on individuals within the ruling government and close associates involved in illicit activities. Although the country itself is not under broad international sanctions, its political environment is often characterized by a lack of transparency, corruption, and human rights violations, which can expose businesses to legal and reputational risks.

Individuals/Entities under Targeted Sanctions:

• Several high-ranking officials in the government of Equatorial Guinea, as well as associated business entities, are subject to targeted sanctions.
• The U.S. Department of Treasury (OFAC) and the European Union have imposed asset freezes and travel bans on individuals within the government, particularly those involved in corrupt practices and human rights violations.
• Companies linked to these individuals, particularly in the oil and gas sector, are often under scrutiny due to the lack of transparency and potential for illicit financial flows.
• Businesses should be vigilant regarding indirect associations with these individuals or entities, especially in sectors like energy, infrastructure, and public contracts.

Recommendations:

• Standard Due Diligence
  • Verify the identities of all business partners, clients, and entities operating in Equatorial Guinea, especially in sectors such as oil, gas, and public contracts, which have higher risks of corruption or illicit activities.
  • Review ownership structures to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and financial transactions to ensure they are legitimate and not linked to sanctioned individuals or entities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions, particularly those involving government contracts, natural resources, or sensitive industries where the risks of corruption and illegal activities are elevated.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to the Equatorial Guinean government or ruling elites.
  • Investigate the ownership and control structures of entities engaged in cross-border transactions or large-scale investments, especially in sectors such as oil and gas, where risks of corruption and illicit financial activity are higher.
• Screen Against Sanctions Lists
  • Regularly screen clients, business partners, and transactions against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to corruption, human rights abuses, or other illicit activities that are subject to international sanctions.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting African countries or the oil and gas sector, where Equatorial Guinea is a key player.
  • Monitor political and economic developments in Equatorial Guinea, particularly any changes in government policy, economic reforms, or potential new international relations that could lead to expanded sanctions.
  • Track changes to international sanctions regimes targeting countries with similar risks, especially those related to corruption, human rights abuses, or transnational criminal activities.

Risk Assessment:

High Risk – Equatorial Guinea presents a high risk in terms of international sanctions. The country is subject to targeted sanctions due to widespread corruption, human rights abuses, and lack of transparency in governance. Businesses operating in Equatorial Guinea, particularly in high-risk sectors such as oil and gas, should conduct rigorous due diligence, remain cautious of indirect exposure to sanctioned individuals or entities, and continuously monitor the evolving political and regulatory landscape to ensure compliance with any future sanctions or regulatory changes.

Eritrea is currently subject to comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, and the United States. The sanctions are primarily related to Eritrea's involvement in regional conflicts, human rights abuses, and its failure to comply with UN Security Council resolutions. These sanctions include asset freezes, travel bans, and restrictions on certain goods, particularly those related to arms and military equipment. While some of these sanctions have been partially lifted in recent years, significant restrictions remain in place. Businesses should be aware of the potential risks associated with engaging in business transactions related to Eritrea, especially in sectors that may involve sensitive goods or entities linked to the government.

Individuals/Entities under Targeted Sanctions:

• Several high-ranking government officials and individuals in Eritrea are subject to targeted sanctions, including asset freezes and travel bans.
• These sanctions are primarily imposed by the United Nations and the European Union, and are often related to human rights abuses, repression of political opposition, and the country's military activities in regional conflicts.
• Entities associated with the Eritrean government, particularly those involved in military and arms trade, are also under sanctions, limiting opportunities for businesses in certain sectors, such as defense and security.
• Businesses should ensure they are not indirectly engaging with individuals or entities subject to these sanctions, particularly in areas like construction, mining, and security services, which may have connections to the government or military.

Recommendations:

• Standard Due Diligence
  • Verify the identities of all business partners, clients, and entities operating in Eritrea, especially in sectors with potential links to the government, military, or entities involved in human rights abuses.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or entities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions, particularly those in sectors such as mining, defense, or construction, where the risks of engaging with government-affiliated entities are higher.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to the Eritrean government or military.
  • Investigate the ownership and control structures of entities involved in cross-border transactions or large-scale investments, particularly in sectors that may be linked to the government or military.
• Screen Against Sanctions Lists
  • Regularly screen all clients, business partners, and transactions against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to human rights violations, regional conflicts, or other activities subject to international sanctions.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Eritrea or the Horn of Africa region.
  • Monitor political and economic developments in Eritrea, particularly any shifts in government policies, military actions, or regional relations that could influence the country’s sanctions status.
  • Track changes to international sanctions regimes, particularly those targeting countries with a history of conflict or human rights abuses, as these may impact Eritrea’s sanctions status.

Risk Assessment:

High Risk – Eritrea presents a high risk in terms of international sanctions. The country is subject to comprehensive sanctions due to its involvement in regional conflicts, human rights abuses, and violations of UN Security Council resolutions. Businesses operating in Eritrea or with connections to the country should conduct thorough due diligence, remain cautious of indirect exposure to sanctioned individuals or entities, and continuously monitor the evolving political and regulatory landscape to ensure compliance with current and future sanctions or regulatory changes.

Estonia is not currently subject to international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a member of both the European Union and NATO, Estonia adheres to international law and regulations, and its political environment is generally stable and transparent. Estonia follows EU sanctions regimes, which are aimed at specific individuals, entities, and countries in response to various geopolitical concerns, such as violations of human rights or involvement in regional conflicts. While Estonia itself is not under sanctions, businesses operating within the country should be aware of the broader EU and international sanctions that may affect their transactions or business dealings, especially in sectors such as finance and trade.

Individuals/Entities under Targeted Sanctions:

• Estonia is not currently subject to comprehensive sanctions. However, as an EU member state, Estonia enforces EU sanctions, which may include asset freezes, travel bans, and other measures targeting individuals, entities, and sectors in countries involved in terrorism, human rights violations, or illegal activities.
• There are no specific individuals or entities in Estonia under targeted sanctions, but businesses operating in Estonia must ensure they are not engaging in transactions with individuals or entities subject to EU, U.S., or UN sanctions.
• Companies in Estonia should also be cautious about potential risks of indirect exposure to sanctioned entities, especially if they are involved in sectors such as finance, energy, or international trade.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Estonia, especially in sectors with higher risks of involvement in illicit activities or links to international sanctions.
  • Review the ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or entities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with industries such as finance, international trade, or sensitive technologies where there may be higher risks of exposure to sanctions violations.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to politically sensitive regions or countries subject to sanctions.
  • Investigate the ownership and control structures of entities involved in cross-border transactions or investments, particularly in sectors that might be linked to sanctioned entities or activities.
• Screen Against Sanctions Lists
  • Regularly screen all clients, business partners, and transactions against global sanctions lists, including those from the EU, UN, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, corruption, or human rights violations, in accordance with international sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting European Union member states, which may influence Estonia’s sanctions policies.
  • Monitor political and economic developments in Estonia, especially any shifts in government policy, trade relations, or potential changes to international obligations that could impact the country’s sanctions status.
  • Track changes to international sanctions regimes, especially those targeting regions or countries that may affect trade and investment opportunities for Estonian businesses.

Risk Assessment:

Low Risk – Estonia presents a low risk in terms of international sanctions. The country adheres to international sanctions regimes and is not subject to broad or targeted sanctions. The political environment is stable and transparent, and the business environment generally aligns with EU and international standards. However, businesses should remain diligent in ensuring compliance with international sanctions, especially those targeting third-party entities or transactions indirectly connected to sanctioned regions or individuals. Regular monitoring of regulatory changes is advisable to stay aligned with global compliance standards.

Eswatini (formerly known as Swaziland) is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country maintains a relatively stable political environment, though it has faced international criticism for its human rights record and the lack of political freedoms, particularly regarding the monarchy’s control over the government. Eswatini is a member of international organizations like the United Nations, but its political and economic environment remains somewhat isolated in comparison to other nations in the Southern African region. While Eswatini is not under broad international sanctions, businesses should be mindful of the potential for future sanctions due to human rights concerns or political developments.

Individuals/Entities under Targeted Sanctions:

• Eswatini itself is not currently subject to international sanctions, but there have been calls from human rights groups for greater scrutiny of the country’s political leadership.
• Certain individuals, particularly within the royal family and government, may be indirectly affected by international criticism or sanctions, especially those related to human rights abuses, suppression of political opposition, and limitations on freedom of speech.
• While there are no prominent targeted sanctions currently in place against individuals or entities from Eswatini, businesses should be cautious about indirect exposure to activities or individuals involved in politically sensitive or repressive actions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Eswatini, particularly in sectors such as government contracts, construction, and mining, where there may be higher risks of corruption or political connections to the monarchy.
  • Review ownership structures to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to politically exposed persons (PEPs) or entities involved in human rights violations.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings in sectors like government contracts, natural resources, or infrastructure, where there may be higher risks of corruption or government involvement.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to the Eswatini monarchy or government officials with significant influence.
  • Investigate the ownership and control structures of entities involved in large-scale or cross-border transactions, especially if these entities have complex ownership or affiliations with high-risk sectors.
• Screen Against Sanctions Lists
  • Regularly screen all clients, business partners, and transactions against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to human rights abuses, corruption, or other activities that could expose businesses to reputational or legal risks.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Southern African countries, as political developments in Eswatini could potentially lead to sanctions or other regulatory actions in the future.
  • Monitor political and economic developments in Eswatini, especially regarding any shifts in government policy, civil unrest, or human rights concerns that could impact the country’s standing in the international community.
  • Track changes to international sanctions regimes, particularly those targeting African countries with similar political climates or human rights concerns, as these could influence the risk profile of Eswatini.

Risk Assessment:

Medium Risk – Eswatini presents a medium risk in terms of international sanctions. While the country is not currently subject to broad sanctions, its political environment, characterized by a lack of political freedoms and human rights concerns, may expose businesses to potential risks. Companies operating in Eswatini should conduct thorough due diligence and remain vigilant to possible future sanctions or regulatory actions. Regular monitoring of political developments, human rights issues, and international relations is advisable to ensure compliance with any changes in the global sanctions landscape.

Ethiopia is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. However, Ethiopia has faced targeted sanctions due to specific political, human rights, and security concerns. The United States, for example, imposed targeted sanctions on Ethiopian individuals and entities, particularly in response to the ongoing conflict in the Tigray region, human rights abuses, and violations of international law. In addition, the European Union has also criticized Ethiopia's human rights record, although it has not implemented broad sanctions. While Ethiopia is not under full international sanctions, the political and humanitarian situation in the country remains a significant concern, and businesses must remain cautious when operating in or with Ethiopia.

Individuals/Entities under Targeted Sanctions:

• Certain individuals and entities in Ethiopia are subject to targeted sanctions, mainly imposed by the U.S. Department of Treasury (OFAC) and the European Union. These sanctions are directed at individuals involved in human rights violations, conflict-related abuses, and the suppression of political opposition, particularly during the Tigray conflict.
• The sanctions include asset freezes, travel bans, and restrictions on U.S. and EU business dealings with these individuals and entities.
• Additionally, entities linked to the Ethiopian military and government officials implicated in the ongoing conflict may be subject to these sanctions.
• Businesses must be vigilant about indirect exposure to individuals or entities involved in or associated with the conflict, especially in sectors such as defense, construction, and energy.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Ethiopia, particularly in sectors that might be linked to the Ethiopian government, military, or individuals involved in conflict zones.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or entities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions, particularly in industries such as defense, energy, and infrastructure, where the risk of association with government-affiliated entities or military operations is higher.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to the Ethiopian government, military, or entities linked to the ongoing conflict.
  • Investigate the ownership and control structures of entities involved in cross-border transactions or large-scale investments, particularly in sectors that could be indirectly linked to sanctioned individuals or the Ethiopian military.
• Screen Against Sanctions Lists
  • Regularly screen clients, business partners, and transactions against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to human rights violations, conflict, or other activities that could result in sanctions under international law.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those related to Ethiopia, as political and humanitarian developments could lead to expanded sanctions or new regulatory actions.
  • Monitor political developments in Ethiopia, particularly any shifts in government policy or the resolution of the Tigray conflict, as these could impact the country’s sanctions status.
  • Track changes to international sanctions regimes targeting countries involved in human rights violations, armed conflicts, or political repression, as these may affect Ethiopia’s standing in the international community.

Risk Assessment:

Medium Risk – Ethiopia presents a medium risk in terms of international sanctions. While the country is not subject to broad or comprehensive sanctions, it has faced targeted sanctions due to its involvement in the Tigray conflict and human rights abuses. Businesses operating in Ethiopia should conduct thorough due diligence and remain cautious about indirect exposure to sanctioned individuals or entities, particularly in sectors linked to the government or military. Continuous monitoring of political and regulatory changes, as well as international sanctions regimes, is advised to ensure compliance and mitigate risks.

Faroe Islands is not subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The Faroe Islands, a self-governing territory within the Kingdom of Denmark, has a stable political and economic environment. Although it is not an EU member, it is closely aligned with the EU through its membership in the European Economic Area (EEA) and its involvement in trade and cooperation agreements. The Faroe Islands generally adhere to international standards and regulations, and it follows the sanctions imposed by Denmark, which are in line with EU and UN sanctions regimes. Therefore, businesses operating in the Faroe Islands must ensure they comply with any sanctions affecting Denmark or the EU.

Individuals/Entities under Targeted Sanctions:

• The Faroe Islands, being part of Denmark's international obligations, do not have individuals or entities specifically targeted for sanctions within the territory.
• However, as a part of Denmark, the Faroe Islands are subject to sanctions imposed by the European Union, the United Nations, and the United States on individuals or entities associated with activities such as terrorism, human rights violations, or regional conflicts.
• Businesses must be cautious about indirect exposure to sanctions linked to Denmark or broader EU regulations, especially in sectors such as finance, trade, and energy, where cross-border connections might lead to unintentional engagement with sanctioned parties.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in the Faroe Islands, especially in sectors where there may be cross-border trade or connections to Denmark.
  • Review ownership structures to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or entities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions, particularly in sectors such as financial services, energy, and trade, where there may be risks of cross-border transactions involving sanctioned individuals or entities.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to regions or activities under international sanctions.
  • Investigate the ownership and control structures of entities involved in cross-border transactions or those with complex international connections.
• Screen Against Sanctions Lists
  • Regularly screen all clients, business partners, and transactions against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, or other activities subject to sanctions.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Denmark and the EU, as changes to these regulations may also impact the Faroe Islands.
  • Monitor political and economic developments in Denmark and the EU, particularly any shifts in sanctions policy or international relations that could affect the Faroe Islands’ compliance with international sanctions.
  • Track changes to international sanctions regimes, particularly those targeting regions or countries with which the Faroe Islands have trade or diplomatic ties.

Risk Assessment:

Low Risk – The Faroe Islands present a low risk in terms of international sanctions. The territory adheres to Denmark's international obligations, and its political and economic environment is stable. While there are no specific sanctions targeting the Faroe Islands, businesses should ensure compliance with EU, UN, and U.S. sanctions, especially when engaging in cross-border transactions or working with individuals or entities that may have international connections. Regular monitoring of regulatory changes and political developments is advisable to stay in compliance with any future adjustments to sanctions regulations.

Finland is not subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a member of the European Union, Finland follows EU sanctions policies, which are based on the EU's commitment to international law, human rights, and security. Finland also adheres to sanctions imposed by the United Nations and the United States, particularly concerning issues such as terrorism, human rights violations, and violations of international law. The country has a stable political and economic environment, and its government is transparent and accountable. While Finland itself is not under sanctions, businesses operating in Finland should be aware of the broader sanctions framework, especially those targeting countries or individuals associated with activities such as corruption, terrorism, or regional conflicts.

Individuals/Entities under Targeted Sanctions:

• Finland does not have individuals or entities specifically targeted by international sanctions within the country. However, Finnish businesses are required to comply with EU sanctions, which may involve asset freezes, travel bans, and other measures targeting individuals and entities in response to activities such as terrorism, corruption, or human rights abuses.
• Finnish companies must also be cautious when dealing with entities or individuals from countries subject to international sanctions, ensuring that no prohibited transactions or investments are made.
• Finland also enforces sanctions related to Russian activities, especially since the conflict in Ukraine escalated, with additional sanctions imposed by both the EU and the U.S. that may impact Finnish businesses, particularly in sectors such as energy, finance, and trade.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Finland, especially in sectors where the risk of exposure to sanctioned parties might be higher, such as finance, energy, and international trade.
  • Review the ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any sanctioned individuals, entities, or governments.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions, particularly in sectors like finance, energy, and defense, where cross-border connections and exposure to high-risk jurisdictions may be higher.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with connections to regions or countries currently under sanctions or involved in high-risk activities.
  • Investigate the ownership and control structures of entities involved in large-scale or cross-border transactions, particularly in cases where the ownership structure is complex or includes jurisdictions with a higher risk of sanctions violations.
• Screen Against Sanctions Lists
  • Regularly screen clients, business partners, and transactions against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure business dealings do not involve individuals or entities linked to criminal activities, terrorism, corruption, or other illicit activities subject to sanctions.
• Monitor for Regulatory Changes
  • Stay informed about updates to EU, U.S., and UN sanctions regulations, particularly those that might affect Finland or its trade partners.
  • Monitor political developments in Finland and in key international regions, particularly concerning the EU's sanctions policies or other geopolitical changes that could affect Finland’s sanctions stance.
  • Track changes to international sanctions regimes, especially those targeting countries in conflict or involved in issues such as human rights violations or state-sponsored terrorism.

Risk Assessment:

Low Risk – Finland presents a low risk in terms of international sanctions. The country adheres to EU and international sanctions regimes, and its political and economic environment is stable and transparent. While Finland itself is not under sanctions, businesses must comply with EU, UN, and U.S. sanctions regulations, especially when dealing with countries or individuals involved in high-risk activities such as terrorism, human rights violations, or regional conflicts. Regular monitoring of regulatory changes and international political developments is recommended to ensure continued compliance.

France is not subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a key member of the European Union and the United Nations Security Council, France plays a significant role in shaping and enforcing international sanctions regimes. France is committed to upholding international law, human rights, and the fight against terrorism. It follows EU sanctions policies and is aligned with U.S. sanctions, particularly in areas related to the prevention of terrorism, the enforcement of human rights, and the prevention of the proliferation of weapons of mass destruction. While France itself is not under sanctions, businesses operating in the country must be aware of the broader sanctions framework, especially those affecting specific individuals, entities, or countries.

Individuals/Entities under Targeted Sanctions:

• France enforces EU and UN sanctions, which include targeted measures such as asset freezes, travel bans, and arms embargoes against individuals and entities involved in terrorism, human rights abuses, or violations of international law.
• There are no specific individuals or entities within France that are targeted for sanctions, but French businesses are subject to compliance with sanctions regulations that apply to entities or individuals from sanctioned countries (e.g., Iran, North Korea, Russia) or those involved in high-risk activities such as money laundering, human rights violations, or corruption.
• France also participates in enforcing sanctions against entities and individuals in conflict zones, such as Syria, Libya, or the Central African Republic, and businesses should be cautious about exposure to entities linked to these regions or activities.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in France, particularly in sectors such as finance, defense, and energy, where there may be higher risks of exposure to sanctioned parties.
  • Review ownership structures to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to individuals, entities, or governments subject to sanctions.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions, particularly in sectors such as defense, energy, and international trade, where the risk of dealing with sanctioned parties may be higher.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with connections to countries or activities under sanctions.
  • Investigate ownership and control structures of entities engaged in large-scale or cross-border transactions, especially where there may be complex ownership arrangements or exposure to high-risk jurisdictions.
• Screen Against Sanctions Lists
  • Regularly screen all clients, business partners, and transactions against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, corruption, or other illicit activities that may result in sanctions.
• Monitor for Regulatory Changes
  • Stay informed about updates to EU, UN, and U.S. sanctions regulations, particularly those affecting France or its international trade partners.
  • Monitor political and economic developments in France, particularly in relation to EU foreign policy and international sanctions regimes, which may change in response to global events or new sanctions imposed by the EU or UN.
  • Track changes to broader international sanctions regimes, especially those targeting countries with which France has significant economic ties or diplomatic relations.

Risk Assessment:

Low Risk – France presents a low risk in terms of international sanctions. The country is highly compliant with EU and UN sanctions regimes and adheres to international standards in upholding the rule of law, human rights, and counter-terrorism measures. While France itself is not under sanctions, businesses must ensure compliance with EU, UN, and U.S. sanctions regulations, particularly when engaging with high-risk sectors or individuals/entities linked to countries subject to sanctions. Regular monitoring of regulatory changes and political developments is recommended to stay informed of any updates that may affect the sanctions landscape.

French Guiana is an overseas department and region of France, and as such, it is subject to the same international sanctions and regulations as mainland France. French Guiana follows France’s compliance with European Union (EU) and United Nations (UN) sanctions, and it is fully aligned with France’s international obligations. The region has a stable political and economic environment as part of France’s territories, but businesses operating in French Guiana should be aware of the broader sanctions frameworks affecting France and the EU, especially those related to human rights, terrorism, and regional conflicts.

Individuals/Entities under Targeted Sanctions:

• French Guiana itself does not have any specific individuals or entities under targeted sanctions. However, because it is an integral part of France, it is subject to EU and UN sanctions imposed on individuals and entities linked to criminal activities, terrorism, human rights abuses, or violations of international law.
• France, including its overseas territories like French Guiana, enforces asset freezes, travel bans, and other measures against individuals, companies, and governments associated with illegal activities or violations of international standards.
• Businesses in French Guiana must be cautious regarding entities or individuals from countries subject to sanctions (e.g., Russia, Iran, North Korea), as they may have connections with these regions or individuals involved in high-risk sectors.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in French Guiana, especially in sectors such as finance, trade, and energy, which could have cross-border connections to sanctioned entities or countries.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or entities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions, especially in sectors with high-risk exposure to international trade, such as finance, energy, and defense, where there may be concerns related to sanctioned individuals or organizations.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to countries under EU, U.S., or UN sanctions.
  • Investigate ownership and control structures of entities involved in cross-border transactions or large-scale investments, especially those with complex ownership arrangements or ties to high-risk jurisdictions.
• Screen Against Sanctions Lists
  • Regularly screen all clients, business partners, and transactions against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, corruption, or other illicit activities that may result in sanctions.
• Monitor for Regulatory Changes
  • Stay informed about updates to EU, UN, and U.S. sanctions regulations, particularly those affecting France, as these will also apply in French Guiana.
  • Monitor political developments in France, including changes to sanctions policies or the resolution of conflicts that may impact the international sanctions landscape.
  • Track changes to broader international sanctions regimes, especially those targeting regions where French Guiana has trade, economic, or diplomatic ties.

Risk Assessment:

Low Risk – French Guiana presents a low risk in terms of international sanctions. As part of France, it adheres to EU and international sanctions regimes, and its political and economic environment is stable. While French Guiana itself is not targeted for sanctions, businesses must comply with France’s obligations under EU, UN, and U.S. sanctions regulations. Regular monitoring of regulatory changes and international political developments is recommended to ensure compliance with any future adjustments to sanctions frameworks.

Gabon is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. Gabon has a stable political environment, although there have been occasional concerns regarding governance and human rights. As a member of the United Nations and the African Union, Gabon generally adheres to international law and maintains diplomatic and trade relations globally. While Gabon is not under full sanctions, businesses should be cautious of potential risks related to corruption, political instability, or illicit activities, which could lead to targeted sanctions in the future.

Individuals/Entities under Targeted Sanctions:

• Currently, there are no prominent individuals or entities within Gabon specifically targeted by international sanctions.
• Gabon, however, complies with international sanctions imposed by bodies such as the United Nations, the European Union, and the United States, particularly those targeting individuals or entities involved in activities like terrorism, human rights abuses, or corruption.
• While Gabon itself is not under sanctions, businesses operating in Gabon must be vigilant about exposure to individuals or entities that may be indirectly linked to international sanctions due to illicit activities or connections to high-risk regions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Gabon, particularly in sectors such as mining, oil, and finance, where the risk of corruption or illicit activities might be higher.
  • Review the ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors linked to government contracts, natural resources, or sensitive industries where there may be higher risks of corruption or illegal activities.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to the Gabonese government or military.
  • Investigate the ownership and control structures of entities engaged in large-scale or cross-border transactions, especially when dealing with offshore entities or complex ownership structures that may be associated with higher risks.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, or corruption, as per the sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting African countries, as changes to Gabon’s political landscape could lead to sanctions or new financial regulations.
  • Monitor political developments in Gabon, particularly any shifts in government policy, economic reforms, or potential changes to international relations that could affect the country’s sanctions status.
  • Track changes to the broader international sanctions regimes, especially those targeting African nations or regions involved in transnational issues such as corruption or instability.

Risk Assessment:

Medium Risk – Gabon presents a medium risk in terms of international sanctions. While the country is not currently subject to comprehensive sanctions, it is important for businesses to be aware of the potential for future sanctions, especially in sectors linked to corruption or illicit activities. The political environment in Gabon, though generally stable, has been marked by concerns about governance, which could expose businesses to higher risks. Standard due diligence should be conducted, with enhanced measures for high-risk sectors or transactions. Continuous monitoring of regulatory and political changes is advised to ensure compliance with evolving sanctions frameworks.

The Gambia is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country has made significant progress in recent years towards democracy and governance, particularly after the change of leadership in 2017, which ended over two decades of authoritarian rule. However, while the political environment is improving, The Gambia has faced challenges related to human rights, governance, and corruption, which could present risks for businesses operating in the country. Though The Gambia is not under full sanctions, businesses should stay alert to the possibility of targeted sanctions due to any future political instability or human rights concerns.

Individuals/Entities under Targeted Sanctions:

• Currently, there are no prominent individuals or entities from The Gambia specifically targeted by international sanctions. However, The Gambia is subject to sanctions imposed by the United Nations, the European Union, and the United States on individuals or entities involved in corruption, human rights violations, or other illicit activities.
• The Gambia adheres to the broader global sanctions regime, including EU and UN sanctions that target individuals or groups involved in the suppression of political opposition, human rights abuses, and other activities contrary to international law.
• While the country itself is not under sanctions, businesses operating in The Gambia must remain vigilant of indirect risks related to sanctions on Gambian individuals or entities linked to illicit activities or politically sensitive areas.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in The Gambia, particularly in high-risk sectors such as government contracts, natural resources, and finance, where corruption or illicit activities may be more prevalent.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any sanctioned individuals or entities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions, particularly in sectors with potential exposure to government officials or entities involved in corruption or human rights issues.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to the Gambian government or military, or those who may be connected to prior administrations.
  • Investigate ownership and control structures of entities involved in large-scale or cross-border transactions, particularly those with complex ownership structures or offshore connections.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, human rights abuses, or corruption.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting African countries, as political developments in The Gambia may lead to the imposition of sanctions or new regulations.
  • Monitor political developments in The Gambia, especially any shifts in government policy or concerns about human rights or governance that could trigger the imposition of targeted sanctions.
  • Track changes to broader international sanctions regimes, particularly those targeting African nations or regions experiencing political instability, human rights violations, or transnational issues such as corruption.

Risk Assessment:

Medium Risk – The Gambia presents a medium risk in terms of international sanctions. While the country is not currently under comprehensive sanctions, there are ongoing challenges related to governance and human rights, which could expose businesses to potential risks. The Gambian government has shown signs of improvement in governance, but the country’s history of political instability and authoritarian rule means that future political developments could lead to targeted sanctions. Businesses should implement standard due diligence, particularly for high-risk sectors, and maintain continuous monitoring for any changes in the political environment or regulatory landscape.

Georgia is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country has made significant strides in aligning itself with Western institutions and has aspirations for closer integration with the European Union and NATO. Despite its geopolitical challenges, especially related to its territorial conflicts with Russia over regions like South Ossetia and Abkhazia, Georgia maintains a relatively stable political environment. However, its proximity to Russia and ongoing territorial disputes could present risks for businesses operating in Georgia, as sanctions related to these conflicts may affect certain individuals or entities within the country.

Individuals/Entities under Targeted Sanctions:

• While Georgia itself is not subject to comprehensive international sanctions, it is important to note that the European Union, the United States, and other international bodies may impose sanctions on specific individuals or entities connected to the ongoing conflict with Russia or linked to activities in the disputed territories of South Ossetia and Abkhazia.
• Georgia adheres to international sanctions frameworks and has cooperated with the EU and UN sanctions targeting individuals or entities involved in terrorism, corruption, or violations of international law, particularly those related to the conflict in its breakaway regions.
• Businesses operating in Georgia must ensure that they are not indirectly linked to individuals or entities under sanctions, particularly those with ties to the Russian government or separatist entities in contested regions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Georgia, especially in high-risk sectors such as construction, defense, and energy, where links to contested regions or Russian entities could pose risks.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or entities involved in the conflict with Russia.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors linked to government contracts, infrastructure development, or sensitive industries that may be exposed to risks related to the conflict in South Ossetia and Abkhazia.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to the Georgian government or individuals with connections to the separatist regions or Russian entities.
  • Investigate ownership and control structures of entities engaged in large-scale or cross-border transactions, especially those with connections to Russian or breakaway region entities.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, or violations of international law, particularly those associated with the Georgian breakaway regions or Russian-linked entities.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting the Caucasus region, as the political situation in Georgia could lead to the imposition of new sanctions or additional restrictions related to the conflict with Russia.
  • Monitor political developments in Georgia, particularly any shifts in government policy, territorial disputes, or international relations that could affect the country’s sanctions status.
  • Track changes to broader international sanctions regimes, especially those targeting regions experiencing territorial disputes or geopolitical tension, such as those involving Georgia’s relationship with Russia.

Risk Assessment:

Medium Risk – Georgia presents a medium risk in terms of international sanctions. While the country is not currently under comprehensive sanctions, the ongoing geopolitical tensions with Russia, particularly over the status of South Ossetia and Abkhazia, mean that there is potential exposure to targeted sanctions. Businesses should conduct standard due diligence and be vigilant about risks associated with the conflict, especially when dealing with high-risk sectors or entities connected to the disputed regions or Russian government interests. Continuous monitoring of political and regulatory developments is advisable to ensure compliance with any changes to sanctions or geopolitical dynamics.

Germany is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a leading member of the European Union and a key player in international diplomacy, Germany adheres to EU sanctions regulations and implements international sanctions in coordination with its allies. Germany maintains a stable political and economic environment, with strong governance institutions and a high level of adherence to international laws. While Germany itself is not under sanctions, businesses should be aware of potential exposure to sector-specific sanctions and compliance requirements related to German entities and individuals subject to international restrictions.

Individuals/Entities under Targeted Sanctions:

• Germany itself is not the target of any international sanctions. However, as a member of the European Union, Germany enforces EU sanctions on individuals and entities involved in activities such as human rights violations, terrorism, corruption, or violations of international law.
• German businesses and individuals may be indirectly affected by sanctions if they engage with individuals or entities from sanctioned countries or regions, such as Russia, Iran, North Korea, or those involved in the ongoing conflicts or human rights abuses.
• There are instances where German companies or individuals have been linked to international sanctions, particularly in industries such as defense, energy, and banking, where international sanctions may target specific activities or transactions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Germany, especially in high-risk sectors such as banking, defense, and energy, where international sanctions could affect transactions or investments.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or entities involved in illicit activities or violations of international law.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors linked to government contracts, defense, energy, or technology, which may be more susceptible to scrutiny under international sanctions.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to foreign governments or entities subject to sanctions by the EU, UN, or U.S.
  • Investigate the ownership and control structures of entities engaged in large-scale or cross-border transactions, especially when dealing with offshore entities or complex ownership structures that may involve sanctioned individuals or regions.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the EU, UN, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, or corruption, as per the sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to EU and global sanctions regulations, particularly those that may affect sectors such as finance, defense, and energy.
  • Monitor political and economic developments in Germany and Europe, particularly any shifts in government policy, foreign relations, or economic sanctions that could affect the country’s sanctions status or impact business operations.
  • Track changes to the broader international sanctions regimes, especially those affecting countries or regions with which Germany has trade, diplomatic, or economic ties.

Risk Assessment:

Low Risk – Germany presents a low risk in terms of international sanctions. The country is a key member of the European Union and adheres to global sanctions regimes, particularly those related to human rights, terrorism, and regional conflicts. Germany’s political and economic environment is stable, and businesses can generally operate without significant exposure to sanctions-related risks. However, companies must remain vigilant regarding sector-specific sanctions, particularly in industries with higher scrutiny, such as defense, finance, and energy, and monitor any potential changes to regulatory frameworks. Standard due diligence and continuous monitoring of international developments are recommended to ensure compliance.

Ghana is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country maintains a stable political environment and is considered one of the more democratic nations in West Africa. Ghana is a member of the United Nations, the African Union, and the Economic Community of West African States (ECOWAS). The country adheres to international standards and regulations, and its foreign policy generally aligns with global norms. However, businesses operating in Ghana should still be aware of potential risks due to its position in a region affected by instability, conflict, and transnational crime, which could lead to the imposition of sanctions in the future.

Individuals/Entities under Targeted Sanctions:

• Ghana itself is not subject to international sanctions. However, the country must comply with global sanctions regimes, including those imposed by the United Nations, the European Union, and the U.S. Department of Treasury (OFAC), targeting individuals or entities involved in illicit activities such as drug trafficking, terrorism, or corruption.
• Ghana’s compliance with international sanctions includes adhering to measures that target individuals or entities linked to transnational crimes, including the illegal trade in goods like minerals or wildlife, and those involved in money laundering or human rights violations.
• While there are no prominent individuals or entities within Ghana directly under international sanctions, businesses must remain cautious of indirect risks from individuals or entities that could be linked to sanctioned organizations or activities.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Ghana, particularly in high-risk sectors such as mining, oil and gas, and finance, where corruption and illicit activities may occur.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any sanctioned individuals or illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with government contracts, mining, or natural resources, which may have higher exposure to corruption or illicit trade activities.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to the government or entities involved in sectors with a higher risk of corruption.
  • Investigate ownership and control structures of entities involved in cross-border transactions or those with complex ownership structures that could be linked to high-risk activities or regions.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, or corruption, as per the sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting African nations and West African countries, as political changes in Ghana could lead to new sanctions or financial regulations.
  • Monitor political developments in Ghana, particularly any shifts in government policy, economic reforms, or changes in international relations that could affect the country’s sanctions status.
  • Track changes to broader international sanctions regimes, especially those targeting African countries or regions involved in transnational issues such as drug trafficking, human rights violations, or corruption.

Risk Assessment:

Low Risk – Ghana presents a low risk in terms of international sanctions. The country is not currently under comprehensive sanctions and has a stable political environment, which is conducive to business operations. While risks do exist, particularly in sectors like mining, finance, and natural resources, Ghana is generally considered a safe environment in terms of sanctions compliance. However, businesses should maintain vigilance regarding due diligence practices, especially in high-risk sectors, and stay informed about any changes to global sanctions or political developments in the region.

Gibraltar is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a British Overseas Territory, Gibraltar follows the sanctions policies of the United Kingdom, which align with EU and international regulations. Gibraltar has a stable political environment, benefiting from its close association with the UK. While it is not under any specific sanctions, its status as a financial center and a location for international trade and services could make it vulnerable to sanctions related to specific individuals, entities, or sectors, especially those with ties to jurisdictions under international scrutiny.

Individuals/Entities under Targeted Sanctions:

• Gibraltar itself is not directly under international sanctions. However, it is subject to the UK’s sanctions regime, which enforces sanctions targeting individuals and entities involved in activities such as terrorism, money laundering, corruption, and other illicit activities.
• The United Kingdom regularly updates its sanctions lists in alignment with global standards, and Gibraltar follows these sanctions. Businesses operating in Gibraltar may need to be cautious of entities or individuals with links to high-risk jurisdictions or those connected to activities such as fraud, corruption, or illicit financial transactions.
• While there are no major individuals or entities within Gibraltar currently under targeted sanctions, businesses must be aware of the risk that specific individuals or entities within the jurisdiction could be sanctioned if involved in illegal activities, particularly in sectors like finance, shipping, and gaming.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Gibraltar, particularly in sectors such as finance, gaming, and shipping, where the risk of illicit activities, including money laundering or financial crime, is higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors connected to international trade, shipping, or financial services, where there may be higher exposure to financial crimes, corruption, or illicit trade.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to high-risk countries or entities under international sanctions.
  • Investigate ownership and control structures of entities involved in complex or cross-border transactions, especially when dealing with offshore entities or those in sectors known for higher risks of illicit activities.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UK, UN, EU, and U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, or corruption, as per the sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to UK and global sanctions regulations, particularly those that may affect sectors such as finance, shipping, or gaming in Gibraltar.
  • Monitor political and economic developments in Gibraltar and the UK, particularly any shifts in government policy or financial regulations that could impact the country’s sanctions status or business operations.
  • Track changes to broader international sanctions regimes, especially those targeting jurisdictions or industries connected to financial crime or illicit trade.

Risk Assessment:

Low Risk – Gibraltar presents a low risk in terms of international sanctions. As a British Overseas Territory, it adheres to the UK's sanctions policies, which are aligned with international standards. While Gibraltar is not subject to comprehensive sanctions, businesses operating in the territory must remain vigilant, particularly in sectors with higher risks such as finance and shipping. Ensuring compliance with AML and CTF regulations and staying informed about updates to global sanctions lists is crucial for mitigating any potential risks. Regular due diligence and monitoring are recommended to ensure compliance with evolving sanctions frameworks.

Greece is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a member of the European Union and NATO, Greece is bound by EU sanctions policies and international obligations. The country maintains a stable political environment, aligned with EU regulations, and adheres to international laws and frameworks. While Greece itself is not under sanctions, businesses should be mindful that sanctions may apply to specific individuals, entities, or sectors, particularly in the context of EU and UN measures that target activities like human rights violations, terrorism, and other illicit conduct.

Individuals/Entities under Targeted Sanctions:

• Greece, as part of the European Union, enforces EU sanctions against individuals, organizations, and countries involved in activities such as terrorism, corruption, money laundering, or violations of international law.
• While Greece itself is not subject to sanctions, Greek entities or individuals may face restrictions if they are linked to individuals or entities in sanctioned countries, such as Russia, Iran, North Korea, or those involved in human rights abuses or other illegal activities.
• Businesses in Greece should be aware of the risk that certain individuals or entities with ties to sanctioned activities may be indirectly impacted by EU or UN sanctions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Greece, especially in high-risk sectors such as finance, shipping, energy, and defense, where international sanctions may be more relevant.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings in sectors such as defense, shipping, and energy, which may involve heightened risks related to international sanctions or geopolitical concerns.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to high-risk countries or sectors with more stringent sanction requirements.
  • Investigate ownership and control structures of entities engaged in large-scale or cross-border transactions, especially if they are involved in offshore dealings or complex ownership arrangements.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the EU, UN, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, or corruption, in accordance with international sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to EU and global sanctions regulations, especially those affecting sectors critical to Greece's economy, such as shipping, energy, and defense.
  • Monitor political and economic developments in Greece and the EU, particularly any shifts in government policy or economic sanctions that could affect the country’s sanctions status.
  • Track changes to the broader international sanctions regimes, especially those targeting countries or regions involved in transnational issues such as corruption, terrorism, or human rights violations.

Risk Assessment:

Low Risk – Greece presents a low risk in terms of international sanctions. The country adheres to EU sanctions regulations, and its political and economic environment is stable. While Greece itself is not under sanctions, businesses should still conduct due diligence to ensure compliance with EU regulations and monitor for potential risks associated with high-risk sectors. Maintaining awareness of international sanctions lists and regulatory changes is essential for mitigating risks, particularly in industries such as shipping, finance, and energy where sanctions-related concerns may be more relevant.

Grenada is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a member of the Caribbean Community (CARICOM) and the Commonwealth of Nations, Grenada adheres to regional and international agreements that promote political stability and compliance with global standards. The country has a stable political environment and a generally positive reputation in the international community. While Grenada itself is not under sanctions, businesses should be aware that certain activities or entities linked to illicit practices or high-risk jurisdictions could lead to future sanctions being imposed, especially if the country becomes involved in activities contrary to international norms, such as money laundering or human rights violations.

Individuals/Entities under Targeted Sanctions:

• Grenada is not under any comprehensive international sanctions, nor are there any prominent individuals or entities in the country that are subject to targeted sanctions.
• However, Grenada is obligated to comply with international sanctions imposed by global bodies, such as the United Nations, the United States (OFAC), and the European Union, which may apply to individuals or entities involved in illicit activities like money laundering, terrorism, or corruption.
• While Grenada itself is not under sanctions, businesses should remain cautious of the risk that individuals or entities linked to Grenada may be involved in transactions or activities that are subject to sanctions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Grenada, particularly in sectors such as finance, tourism, and offshore services, where there may be an increased risk of illicit activities.
  • Review the ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not connected to any sanctioned individuals or entities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings involving sectors such as offshore finance, real estate, and government contracts, where there may be a higher risk of corruption or illicit trade.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with links to high-risk countries or sectors.
  • Investigate the ownership and control structures of entities engaged in complex or cross-border transactions, especially those that might involve high-risk jurisdictions.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities that are linked to terrorism, corruption, or other illicit activities, as specified in international sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Caribbean nations or offshore financial hubs, as Grenada could become subject to future sanctions or new financial regulations.
  • Monitor political and economic developments in Grenada, particularly any changes in government policy or economic relationships that could affect the country’s sanctions status.
  • Track changes to broader international sanctions regimes, especially those targeting regions or countries involved in transnational issues such as money laundering, tax evasion, or terrorism.

Risk Assessment:

Low Risk – Grenada presents a low risk in terms of international sanctions. The country is not under comprehensive sanctions and has a stable political and economic environment. While there may be risks related to certain sectors like offshore finance or real estate, Grenada is generally considered to be low risk for sanctions-related issues. However, businesses operating in Grenada should remain vigilant, especially in high-risk sectors, and ensure compliance with due diligence procedures to mitigate any potential exposure to illicit activities. Regular monitoring of sanctions lists and regulatory updates is recommended to stay ahead of any potential changes in the country’s sanctions status.

Guatemala is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country maintains a stable political environment but has faced challenges related to corruption, human rights concerns, and organized crime, which could impact its international standing. Guatemala is a member of international organizations such as the United Nations and the Organization of American States (OAS), which obligate it to comply with various international norms and sanctions regimes. While Guatemala itself is not directly under sanctions, businesses should be mindful that sanctions may apply to specific individuals, entities, or sectors, particularly those linked to illicit activities such as drug trafficking or corruption.

Individuals/Entities under Targeted Sanctions:

• While Guatemala as a country is not under comprehensive international sanctions, certain individuals and entities within Guatemala may be subject to targeted sanctions imposed by international bodies, especially the U.S. Department of the Treasury (OFAC). These sanctions typically target individuals or entities involved in activities such as drug trafficking, corruption, and human rights abuses.
• Guatemala is subject to sanctions and watchlists from the U.S. and the EU, which may include restrictions on individuals or businesses linked to organized crime, illegal mining, and corrupt government officials.
• Businesses in Guatemala should be cautious of any indirect exposure to sanctioned entities or individuals, especially those involved in sectors prone to illicit activities.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Guatemala, especially in sectors such as mining, agriculture, and government contracts, which can be more prone to corruption or illegal activities.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any sanctioned individuals or illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with high-risk sectors such as real estate, natural resources, and government contracts, where the risks of corruption or illegal dealings may be higher.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to the Guatemalan government or law enforcement agencies that may be involved in corruption or human rights abuses.
  • Investigate ownership and control structures of entities engaged in large-scale or cross-border transactions, especially when dealing with offshore entities or complex ownership structures that may pose higher risks.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, corruption, or human rights violations, in line with international sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Latin American countries or regions with high levels of organized crime and corruption, as changes to Guatemala’s political landscape could lead to sanctions or new financial regulations.
  • Monitor political developments in Guatemala, particularly any shifts in government policy, economic reforms, or changes in international relations that could affect the country’s sanctions status.
  • Track changes to the broader international sanctions regimes, especially those targeting countries or regions involved in transnational issues such as drug trafficking, corruption, or human rights abuses.

Risk Assessment:

Medium Risk – Guatemala presents a medium risk in terms of international sanctions. While the country is not subject to comprehensive sanctions, its challenges with corruption, organized crime, and human rights issues can result in targeted sanctions against specific individuals or entities within the country. Businesses operating in Guatemala should conduct thorough due diligence, especially in sectors with higher risks of illicit activities, and regularly monitor political and economic developments. Continuous screening against global sanctions lists and staying up-to-date with regulatory changes will help mitigate any potential exposure to sanctioned individuals or entities.

Guinea is currently subject to some international sanctions, particularly from the United Nations, the European Union, and the United States. The sanctions have been imposed due to concerns over human rights violations, political instability, and the lack of progress towards democracy following the military coup in 2021. These sanctions primarily target individuals and entities involved in the military junta, the suspension of the constitution, and the use of force to suppress opposition. Guinea’s political environment remains unstable, and businesses operating there should be mindful of the evolving nature of sanctions and regulatory compliance.

Individuals/Entities under Targeted Sanctions:

• Several individuals, including members of the military junta that came to power in the 2021 coup, are subject to targeted sanctions, including travel bans, asset freezes, and restrictions on financial transactions.
• The European Union, United States (OFAC), and the United Nations have imposed sanctions on individuals and entities associated with the military regime and those involved in human rights abuses or undermining democracy.
• While Guinea itself is not subject to comprehensive international sanctions, there are significant risks for businesses interacting with the government or military, as transactions involving sanctioned individuals or entities may result in secondary sanctions or reputational damage.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Guinea, especially in sectors such as natural resources, mining, and government contracts, where risks of corruption or illegal activities may be higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or entities involved in illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with entities or sectors connected to the government, military, or natural resources industries, where there is an increased risk of involvement in corruption or human rights abuses.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with direct ties to the military junta or government officials facing sanctions.
  • Investigate ownership and control structures of entities engaged in cross-border transactions, particularly those involving offshore companies or complex ownership arrangements that may be associated with higher risks.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to the military regime or involved in human rights violations, corruption, or undermining democracy, as per the sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting African nations, as the political instability in Guinea could lead to further sanctions or financial restrictions.
  • Monitor political developments in Guinea, particularly any changes in the government’s stance on democracy, the rule of law, and human rights, which may impact the country’s sanctions status.
  • Track changes to the broader international sanctions regimes, especially those targeting countries involved in issues such as military coups, human rights violations, or corruption.

Risk Assessment:

High Risk – Guinea presents a high risk in terms of international sanctions. The country’s political instability and ongoing military rule, along with concerns over human rights abuses, make it a high-risk environment for businesses. Companies operating in Guinea must exercise heightened due diligence, particularly in sectors linked to the government and military. Continuous monitoring of global sanctions lists, political developments, and regulatory changes is essential to ensure compliance and avoid inadvertent involvement with sanctioned entities or individuals.

Guinea-Bissau is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. However, the country has faced challenges related to political instability, drug trafficking, and governance issues, which have attracted international attention. While Guinea-Bissau is not under broad sanctions, the international community, including the United States and the European Union, has imposed targeted sanctions on individuals and entities linked to corruption, organized crime, and destabilizing activities. The country’s political environment remains unstable, with frequent changes in government and military influence, which could increase the risk of future sanctions.

Individuals/Entities under Targeted Sanctions:

• Certain individuals in Guinea-Bissau, primarily those associated with drug trafficking, corruption, and organized crime, are subject to targeted sanctions from international bodies, including the United Nations and the U.S. Department of Treasury (OFAC). These sanctions typically involve travel bans, asset freezes, and restrictions on financial transactions.
• The European Union has also imposed sanctions on individuals involved in undermining democratic processes and human rights abuses, including military leaders and politicians linked to coup attempts and political violence.
• While Guinea-Bissau as a country is not under comprehensive sanctions, businesses must remain vigilant about the potential risks of engaging with individuals or entities involved in illicit activities such as drug trafficking or corruption.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Guinea-Bissau, particularly in sectors such as government contracts, natural resources, and the narcotics trade, where the risk of corruption and illicit activities is higher.
  • Review the ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with high-risk sectors such as natural resources (e.g., mining, oil) or sectors with ties to the military or political elite, where the risks of corruption or illegal activity may be heightened.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with links to the government or military in Guinea-Bissau.
  • Investigate the ownership and control structures of entities engaged in cross-border transactions, especially those involving offshore entities or complex ownership arrangements that may be linked to higher risks.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, corruption, or human rights violations, in accordance with international sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting African nations with high levels of political instability or involvement in transnational issues such as drug trafficking or corruption.
  • Monitor political developments in Guinea-Bissau, particularly any shifts in government, military involvement, or changes in international relations that could lead to future sanctions.
  • Track changes to broader international sanctions regimes, especially those targeting countries or regions involved in organized crime, human rights abuses, or political instability.

Risk Assessment:

Medium to High Risk – Guinea-Bissau presents a medium to high risk in terms of international sanctions. Although the country is not under comprehensive sanctions, its political instability, corruption, and links to transnational crimes such as drug trafficking make it a high-risk environment. Businesses should exercise thorough due diligence, particularly in sectors linked to the government or military. Continuous monitoring of global sanctions lists, political developments, and regulatory changes is essential to mitigate the risk of inadvertent involvement with sanctioned individuals or entities.

Guyana is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country has a relatively stable political environment and is a member of several international organizations, including the United Nations and the Caribbean Community (CARICOM). Guyana has made significant strides in its economic development, particularly due to its recent oil discoveries. However, it faces challenges related to governance, corruption, and human rights issues, which could increase its vulnerability to targeted sanctions in the future.

While Guyana itself is not under sanctions, businesses should remain cautious and monitor the potential risks of dealing with individuals or entities involved in illicit activities such as corruption, money laundering, or environmental violations.

Individuals/Entities under Targeted Sanctions:

• As of now, there are no prominent individuals or entities from Guyana subject to international sanctions. However, Guyana complies with international sanctions regimes, particularly those imposed by the United Nations and the U.S. Department of Treasury (OFAC), and businesses should be aware of any indirect risks related to entities involved in illegal activities, such as drug trafficking or corruption.
• Guyana may be at risk of being associated with individuals or entities from other regions that are under sanctions, and businesses should remain vigilant about potential exposure to these risks, particularly in sectors prone to illicit financial flows or environmental violations.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Guyana, especially in sectors such as oil and gas, mining, and government contracts, where risks of corruption or illicit activities might be higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors such as natural resources, where the risks of corruption, environmental violations, or illegal activities may be elevated.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to the Guyanese government, political parties, or state-owned entities.
  • Investigate the ownership and control structures of entities engaged in large-scale or cross-border transactions, particularly those involving offshore companies or complex ownership structures that may be linked to higher risks.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, corruption, or human rights violations, in line with sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting the Caribbean region or countries with emerging natural resource industries.
  • Monitor political developments in Guyana, particularly any shifts in government policy, economic reforms, or potential changes to international relations that could affect the country’s sanctions status.
  • Track changes to broader international sanctions regimes, especially those targeting regions involved in environmental issues, corruption, or organized crime.

Risk Assessment:

Low to Medium Risk – Guyana presents a relatively low to medium risk in terms of international sanctions. The country is not under comprehensive sanctions, and its political and economic environment remains relatively stable. However, the emerging oil industry and governance challenges, including corruption, could expose businesses to certain risks. Businesses should conduct standard due diligence, particularly in high-risk sectors, and monitor political and regulatory developments to ensure compliance with any future sanctions or regulatory changes.

Haiti is currently subject to a range of international sanctions, particularly from the United States, the European Union, and the United Nations, due to its political instability, corruption, and human rights violations. The sanctions were primarily imposed following the 2004 political crisis, the overthrow of President Aristide, and continued governance challenges, including gang violence, political unrest, and corruption. While Haiti is not under comprehensive sanctions, several individuals and entities involved in the government, security services, and criminal organizations are subject to targeted sanctions, including asset freezes and travel bans. The ongoing political and social instability makes Haiti a high-risk jurisdiction for businesses and international trade.

Individuals/Entities under Targeted Sanctions:

• Several individuals in Haiti, including political figures, business leaders, and members of criminal organizations, are subject to targeted sanctions imposed by the U.S. Department of Treasury (OFAC), the United Nations, and the European Union. These sanctions primarily involve asset freezes, travel bans, and restrictions on financial transactions.
• The individuals and entities targeted by sanctions are generally linked to corruption, human rights abuses, violent criminal activities (e.g., gang violence), and undermining democratic processes.
• Haiti has been subject to ongoing scrutiny by international organizations regarding its political and governance issues, which could lead to further targeted sanctions or financial restrictions if the situation deteriorates.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Haiti, particularly in sectors such as government contracts, infrastructure, and natural resources, where the risk of corruption or illicit activities may be higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or entities involved in illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors such as construction, energy, and government-related projects, where there is a higher risk of involvement with corrupt practices or criminal organizations.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to the Haitian government or security forces.
  • Investigate the ownership and control structures of entities engaged in large-scale or cross-border transactions, especially those involving offshore entities or complex ownership arrangements linked to higher risks.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, corruption, or human rights violations, in accordance with international sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting the Caribbean and countries with political instability or associated with transnational organized crime.
  • Monitor political developments in Haiti, especially changes in government, potential shifts in international relations, and efforts to address corruption or human rights issues, as these could lead to changes in the country’s sanctions status.
  • Track changes to broader international sanctions regimes, especially those targeting regions involved in organized crime, violence, or corruption.

Risk Assessment:

High Risk – Haiti presents a high risk in terms of international sanctions. The country’s ongoing political instability, governance challenges, and issues with corruption and criminal organizations make it a high-risk environment for businesses. Companies operating in Haiti must conduct enhanced due diligence, especially in sectors linked to the government or high-value projects, and continuously monitor global sanctions lists, political developments, and regulatory changes to ensure compliance and mitigate exposure to sanctions.

Holy See (Vatican City) is not subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The Holy See is a sovereign entity and the governing body of the Roman Catholic Church, and it maintains diplomatic relations with most countries. Due to its unique religious and political role, the Holy See is not typically targeted by broad sanctions. However, the Vatican has faced scrutiny regarding issues such as money laundering, financial transparency, and the handling of abuse cases, which could potentially expose it to international scrutiny or limited sanctions in the future, particularly in relation to financial activities.

The Holy See adheres to international sanctions regulations, including those implemented by the European Union and the United States, especially with respect to financial transactions and anti-money laundering (AML) and counter-terrorism financing (CTF) measures. Despite its exemption from general sanctions, businesses should remain vigilant, particularly when engaging in transactions involving Vatican entities or affiliated organizations.

Individuals/Entities under Targeted Sanctions:

• There are no prominent individuals or entities within the Holy See itself that are currently subject to targeted international sanctions. However, individuals associated with Vatican-related entities, such as those involved in financial misconduct, may come under scrutiny or sanctions imposed by international authorities, particularly if involved in illicit financial activities.
• The Holy See is committed to compliance with international financial regulations and has taken steps in recent years to improve its financial transparency and anti-money laundering efforts to avoid being associated with illicit activities.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in or with Vatican-affiliated organizations, particularly in sectors such as finance, real estate, and charitable activities, where financial transactions may be more opaque.
  • Review the ownership structures and control of organizations linked to the Holy See to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any illicit activities or entities under sanctions.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors that are more vulnerable to money laundering or corruption, such as charitable donations, art sales, or financial transactions.
  • Scrutinize transactions involving politically exposed persons (PEPs) who may have associations with the Vatican’s internal affairs, especially in relation to financial activities.
  • Investigate complex ownership structures or cross-border financial transactions involving Vatican-related entities to ensure they comply with international regulations and are not linked to illicit activities.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, money laundering, or human rights violations, as per international sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations and financial transparency laws, particularly those affecting sovereign states or organizations with international influence.
  • Monitor changes in Vatican City’s internal regulations or its international financial dealings, as increased scrutiny or potential new regulations could alter the landscape for businesses operating in or with the Holy See.
  • Track developments in global financial regulations and anti-money laundering (AML) measures that could impact Vatican-related entities or organizations, especially in light of past criticisms or legal cases involving financial transparency.

Risk Assessment:

Low Risk – The Holy See presents a low risk in terms of international sanctions. As a sovereign entity, the Vatican is not subject to broad sanctions. It has made efforts to improve financial transparency and comply with international regulations, particularly in relation to anti-money laundering. While the Holy See is not a target of general sanctions, businesses should still ensure due diligence, especially in sectors such as finance and charity, where there could be exposure to illicit financial flows or criminal activities. Monitoring any changes in regulations and ensuring compliance with international financial standards is advisable.

Honduras is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. However, the country faces significant political, social, and security challenges, including high levels of corruption, organized crime, and human rights violations. These factors make Honduras a country at risk for the imposition of further sanctions, particularly targeted sanctions against individuals or entities involved in corruption, narcotics trafficking, or violence. While Honduras itself is not under sanctions, businesses operating in the country should remain vigilant due to the risk of encountering parties involved in illicit activities that are subject to international sanctions.

Individuals/Entities under Targeted Sanctions:

• Several individuals and entities in Honduras have been placed under targeted sanctions by the United States, particularly by the U.S. Department of Treasury (OFAC). These sanctions typically involve asset freezes, travel bans, and prohibitions on conducting business with these individuals or entities. The sanctions primarily target individuals involved in narcotics trafficking, organized crime, and corruption, including high-ranking officials and business leaders linked to illicit activities.
• The United Nations and European Union also impose sanctions on individuals and entities involved in criminal activities, but these sanctions are generally more limited in scope and focus on specific individuals involved in activities such as drug trafficking and corruption.
• Businesses must be aware that even if the country is not subject to comprehensive sanctions, there is the risk of indirect exposure through dealings with individuals or entities involved in illicit activities.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Honduras, particularly in sectors such as construction, government contracts, and mining, where the risk of corruption or illicit activities may be higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or entities involved in criminal activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors linked to government contracts, natural resources, or industries where there may be higher risks of corruption or criminal activities.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to the Honduran government, security forces, or individuals under U.S. sanctions.
  • Investigate the ownership and control structures of entities engaged in large-scale or cross-border transactions, especially when dealing with offshore entities or complex ownership structures linked to higher risks.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, corruption, or human rights violations, in accordance with sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Central American countries, as the political landscape in Honduras is volatile and may lead to new sanctions or regulations.
  • Monitor political developments in Honduras, particularly any changes in government policy, the fight against corruption, or efforts to address organized crime, as these could lead to sanctions or new regulations.
  • Track changes to broader international sanctions regimes, especially those targeting Latin American countries involved in drug trafficking, corruption, or human rights abuses.

Risk Assessment:

Medium to High Risk – Honduras presents a medium to high risk in terms of international sanctions due to its ongoing challenges with corruption, organized crime, and human rights issues. While the country is not under comprehensive sanctions, there is a significant risk of encountering individuals or entities subject to targeted sanctions, particularly in sectors linked to government contracts or illicit activities. Businesses should conduct enhanced due diligence, especially in high-risk sectors, and continuously monitor political developments and regulatory changes to ensure compliance with international sanctions and avoid exposure to illicit financial activities.

Hong Kong is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. However, following the imposition of the National Security Law (NSL) by China in 2020, there have been significant changes to Hong Kong's political landscape. The law has been criticized by many countries and organizations for undermining the region's autonomy and its freedoms, leading to sanctions imposed by several Western countries, especially the United States. These sanctions are typically targeted, affecting individuals and entities linked to the enforcement of the National Security Law or other activities deemed to undermine Hong Kong’s autonomy and human rights.

As Hong Kong operates under the "one country, two systems" framework, businesses and international entities should be aware of the potential for changes in regulations or further sanctions that could impact operations, especially for entities or individuals involved in activities related to the NSL or political dissent.

Individuals/Entities under Targeted Sanctions:

• Several individuals and entities in Hong Kong have been targeted by the United States, particularly under sanctions imposed by the U.S. Department of Treasury (OFAC) in response to the imposition of the National Security Law. These sanctions include asset freezes and travel bans and generally focus on individuals involved in the enforcement of the law or political repression.
• The European Union has also implemented sanctions on individuals linked to the erosion of freedoms in Hong Kong, although the scope of the sanctions is narrower than that of the U.S. measures.
• The United Nations has not implemented comprehensive sanctions on Hong Kong, but it has expressed concern about the erosion of freedoms and autonomy. Global financial institutions and other stakeholders must remain aware of these developments as potential sanctions could expand.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Hong Kong, especially those involved in sectors like finance, real estate, or government-related activities, where there could be links to sanctioned individuals or entities.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to individuals or entities involved in politically sensitive activities or sanctions violations.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors that are sensitive to political developments, such as finance, media, or public services.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to the Hong Kong government or Chinese officials involved in the enforcement of the National Security Law.
  • Investigate the ownership and control structures of entities engaged in large-scale or cross-border transactions, especially when dealing with complex ownership structures or entities with ties to government or political figures.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to the enforcement of the National Security Law or activities that may be considered violations of international human rights standards.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Hong Kong, as the political environment in the region may lead to further sanctions or financial restrictions.
  • Monitor political developments in Hong Kong, especially any changes related to the enforcement of the National Security Law, civil liberties, and the autonomy of the region, as these could lead to an expansion of sanctions.
  • Track changes to broader international sanctions regimes, especially those targeting China or regions involved in human rights violations or political repression.

Risk Assessment:

Medium to High Risk – Hong Kong presents a medium to high risk in terms of international sanctions. While the region itself is not under comprehensive sanctions, the imposition of targeted sanctions on individuals and entities associated with the National Security Law and political repression poses risks for businesses. Companies operating in Hong Kong should ensure rigorous due diligence, especially when dealing with politically sensitive sectors or individuals linked to the government or the enforcement of controversial laws. Monitoring the political and regulatory landscape is essential for businesses to mitigate risks and maintain compliance with international sanctions.

Hungary is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a member of the European Union and NATO, Hungary adheres to the EU's foreign policy and sanctions regimes, which includes sanctions against countries, entities, and individuals involved in activities such as terrorism, human rights violations, or unlawful annexations. However, Hungary has occasionally been criticized by the EU and international organizations for its domestic policies on issues like rule of law, judicial independence, and freedom of the press. Despite these criticisms, Hungary has not been directly targeted by comprehensive sanctions.

Businesses operating in Hungary should be aware that the country’s domestic policies, including its relations with Russia, may lead to targeted sanctions on individuals or entities involved in activities of concern to the EU or other global powers.

Individuals/Entities under Targeted Sanctions:

• Hungary itself is not under sanctions, but some Hungarian individuals and entities may be subject to targeted sanctions, primarily by the United States or the European Union. These sanctions typically involve asset freezes and travel bans.
• The sanctions often focus on individuals involved in activities like corruption, human rights violations, or undermining democratic institutions. Additionally, there have been concerns over Hungary’s relationship with Russia, which could result in increased scrutiny of individuals or entities with links to Russia.
• Businesses must be vigilant in ensuring that their partners in Hungary are not involved in any activities that may attract these types of sanctions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Hungary, especially in sectors such as finance, real estate, and government contracts, where the risk of corruption or illicit activities may be higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to individuals or entities under sanctions or involved in illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors that may be more prone to corruption or illicit activities, such as energy, construction, or government-linked industries.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to the Hungarian government, or individuals linked to controversial policies or human rights concerns.
  • Investigate the ownership and control structures of entities engaged in cross-border transactions, especially when dealing with complex ownership structures or companies linked to sensitive political or economic interests.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, corruption, or human rights violations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting EU member states, as Hungary’s political position could result in additional scrutiny or sanctions.
  • Monitor developments related to Hungary’s foreign policy, particularly its relationship with Russia and the European Union, as this could lead to potential sanctions or regulatory changes that affect businesses in Hungary.
  • Track any shifts in Hungary’s domestic policies related to rule of law, press freedom, and democracy, as these could trigger targeted sanctions or new international regulations.

Risk Assessment:

Medium Risk – Hungary presents a medium risk in terms of international sanctions. While the country is not under comprehensive sanctions, certain individuals and entities within Hungary may be subject to targeted sanctions, particularly those linked to corruption, human rights concerns, or Russia. Businesses operating in Hungary should conduct standard due diligence and be prepared for enhanced scrutiny, particularly in sectors linked to government contracts or politically sensitive industries. Continuous monitoring of political developments and international relations is essential to ensure compliance with any future regulatory changes or sanctions.

Iceland is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a member of the European Economic Area (EEA) and the Schengen Area, Iceland adheres to the foreign policy and sanctions regimes of the European Union. This means that while Iceland itself is not targeted by sanctions, it implements and enforces EU sanctions against countries, individuals, and entities involved in activities such as terrorism, human rights abuses, or violations of international law. Iceland generally maintains a neutral foreign policy and is committed to international peace, democracy, and human rights.

Given Iceland's strong adherence to EU foreign policy and its international partnerships, businesses operating in the country are unlikely to face direct sanction-related risks unless they are involved in transactions or partnerships with entities or individuals already subject to international sanctions.

Individuals/Entities under Targeted Sanctions:

• Iceland does not have any domestic entities or individuals currently subject to international sanctions. However, as part of the EU, Iceland enforces EU-wide sanctions, which may include asset freezes, travel bans, and other restrictions on individuals and entities involved in illicit activities such as terrorism, human rights violations, or the illegal acquisition of weapons of mass destruction.
• Iceland also adheres to the UN sanctions, which could apply to entities or individuals involved in similar activities.
• Businesses operating in Iceland must screen their clients, partners, and transactions to ensure they are not indirectly engaging with individuals or entities subject to these sanctions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Iceland, especially in sectors like finance, real estate, and energy, where the risk of money laundering or illicit activities may be higher.
  • Review the ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to any sanctioned individuals or entities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions, particularly in sectors linked to government contracts, natural resources, or sensitive industries, which may involve higher risks of corruption or illicit activity.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to foreign governments or individuals that may be subject to international sanctions.
  • Investigate the ownership and control structures of entities involved in cross-border transactions, especially those with complex ownership structures or offshore entities that may involve heightened risks.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, or human rights violations, in accordance with sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting European Economic Area (EEA) countries, as Iceland adheres to EU sanctions and regulations.
  • Monitor political and foreign policy developments in Iceland, particularly those relating to its EU membership, to ensure compliance with any changes to international sanctions or trade policies.
  • Track changes in global sanctions regimes, especially those affecting countries or regions involved in issues such as human rights, arms proliferation, or other illegal activities.

Risk Assessment:

Low Risk – Iceland presents a low risk in terms of international sanctions. The country adheres to EU and UN sanctions regimes, and its stable political environment, high standards of governance, and commitment to human rights make it a relatively low-risk jurisdiction for sanctions compliance. However, businesses should continue to conduct standard due diligence, particularly in sectors with higher risks of illicit financial activities or politically sensitive transactions, and ensure ongoing monitoring for any regulatory or sanctions-related changes.

India is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. India is a prominent member of several international organizations, including the United Nations, BRICS, and the World Trade Organization (WTO), and generally aligns with international norms and regulations. While India maintains a generally positive international reputation, it has faced some scrutiny due to its foreign policy stance, particularly regarding relations with certain countries, such as Russia and Iran. However, India itself is not under any comprehensive international sanctions.

That being said, India does impose domestic sanctions and has certain measures related to terrorism and corruption, which align with international efforts. The country also has a history of imposing restrictions on entities and individuals involved in corruption, human rights violations, or national security issues, but these are generally limited to specific cases and are not widespread across the economy.

Individuals/Entities under Targeted Sanctions:

• India itself is not under international sanctions, but some Indian individuals and entities may be subject to targeted sanctions. These sanctions typically involve asset freezes, travel bans, or restrictions on specific activities related to terrorism or illicit trade.
• The United States, under the U.S. Department of Treasury's Office of Foreign Assets Control (OFAC), has imposed targeted sanctions on individuals and entities related to issues such as terrorism or nuclear proliferation. These sanctions are typically related to specific individuals or organizations rather than being broadly imposed on the Indian government or its economy.
• India is generally proactive in cooperating with international anti-terrorism measures and counter-proliferation efforts, but businesses must be aware of the potential for indirect exposure to sanctioned entities or individuals linked to terrorism, organized crime, or corruption.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in India, particularly those involved in sectors such as finance, real estate, and defense, where risks of corruption or illicit activities may be higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to individuals or entities involved in sanctioned activities or illegal dealings.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions, particularly in sectors with higher corruption risks, such as government contracting, defense, or natural resources.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with links to Indian government officials or individuals in sectors prone to bribery and corruption.
  • Investigate the ownership and control structures of entities involved in large-scale or cross-border transactions, especially when dealing with offshore entities or complex ownership structures that may involve heightened risks.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to terrorism, nuclear proliferation, corruption, or any criminal activities subject to sanctions.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting India and its international relations, as the country's foreign policy could result in indirect exposure to sanctioned entities or individuals.
  • Monitor developments in India’s political and security landscape, particularly in relation to its international relations with countries like Russia, Iran, and others subject to sanctions.
  • Track changes in international sanctions regimes, especially those targeting terrorism, nuclear proliferation, or organized crime, which may impact India indirectly.

Risk Assessment:

Medium Risk – India presents a medium risk in terms of international sanctions. While the country itself is not under comprehensive sanctions, certain individuals and entities within India may be subject to targeted sanctions related to terrorism, nuclear proliferation, or corruption. Businesses operating in India should ensure they conduct standard due diligence, particularly in sectors with higher risks of illicit activities, and should stay vigilant for any changes in the political and regulatory landscape. Continuous monitoring is essential to mitigate the risks of exposure to individuals or entities that may become subject to sanctions in the future.

Indonesia is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. Indonesia is a member of several international organizations, including the United Nations, the Association of Southeast Asian Nations (ASEAN), and the World Trade Organization (WTO). The country generally adheres to international norms and plays an active role in regional diplomacy and trade. Indonesia maintains a neutral foreign policy and engages with a wide range of global partners, including both Western and non-Western countries.

Although Indonesia is not under broad sanctions, certain individuals or entities within the country may be subject to targeted sanctions due to their involvement in illicit activities such as terrorism, drug trafficking, or corruption. Indonesia has taken steps to address these issues by cooperating with international organizations on anti-terrorism, anti-money laundering (AML), and counter-proliferation efforts.

Individuals/Entities under Targeted Sanctions:

• Indonesia itself is not subject to comprehensive international sanctions, but some individuals and entities within the country may be subject to targeted sanctions. These sanctions are typically imposed by bodies like the United States, the European Union, or the United Nations.
• Targeted sanctions often focus on individuals or groups linked to terrorism, organized crime, corruption, or violations of human rights. The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) and the United Nations Security Council have listed certain individuals and entities involved in such activities in Indonesia.
• Businesses should be vigilant in screening their partners and transactions to avoid indirect dealings with those who may be involved in illicit activities subject to sanctions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Indonesia, especially in sectors such as mining, energy, and finance, where the risk of corruption or illicit activities might be higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to individuals or entities involved in sanctioned activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions, particularly in sectors linked to government contracts, natural resources, or sensitive industries, which may have higher risks of corruption or illegal activities.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to the Indonesian government or military.
  • Investigate the ownership and control structures of entities engaged in large-scale or cross-border transactions, particularly when dealing with offshore entities or complex ownership structures.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to criminal activities, terrorism, or corruption, in compliance with sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Southeast Asia, as changes in Indonesia’s political landscape or international relations could lead to new sanctions or financial regulations.
  • Monitor political developments in Indonesia, particularly any shifts in government policy, economic reforms, or potential changes to international relations that could affect the country’s sanctions status.
  • Track changes to the broader international sanctions regimes, especially those targeting terrorism, human rights abuses, or organized crime, which may affect Indonesia indirectly.

Risk Assessment:

Medium Risk – Indonesia presents a medium risk in terms of international sanctions. While the country itself is not under comprehensive sanctions, certain individuals and entities may be subject to targeted sanctions related to terrorism, corruption, or human rights violations. Businesses operating in Indonesia should conduct standard due diligence and monitor political developments closely. Enhanced due diligence should be applied to high-value transactions and partnerships in sectors prone to corruption or illicit activities. Regular screening against sanctions lists and vigilance regarding regulatory changes will help mitigate potential risks.

Iran is subject to comprehensive international sanctions imposed by major regulatory bodies, including the United Nations, the European Union, and the United States. These sanctions are a result of Iran’s nuclear program, its involvement in regional conflicts, and its support for groups designated as terrorist organizations. The United States, in particular, has imposed stringent sanctions under the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC), which target various sectors of the Iranian economy, including banking, oil and gas, and shipping. The United Nations and the European Union have also enacted sanctions related to human rights violations, ballistic missile development, and support for militant groups.

Despite some temporary relief in the form of sanctions waivers and agreements like the Joint Comprehensive Plan of Action (JCPOA), many of these sanctions have been reimposed or tightened, particularly following the U.S. withdrawal from the nuclear deal in 2018. Consequently, businesses operating in or with Iran face significant risks related to compliance with international sanctions.

Individuals/Entities under Targeted Sanctions:

• Iran is subject to extensive international sanctions, which include asset freezes, travel bans, and other restrictions on its government officials, entities, and individuals linked to the country’s nuclear, ballistic missile, and terrorism-related activities.
• The U.S. Department of Treasury (OFAC) maintains a comprehensive sanctions list, which includes Iranian government officials, entities within the energy and financial sectors, as well as individuals linked to organizations such as Hezbollah, the Islamic Revolutionary Guard Corps (IRGC), and various militant groups in the Middle East.
• The European Union also targets specific Iranian entities involved in human rights abuses, regional destabilization, and proliferation activities.
• Any engagement with Iranian businesses, financial institutions, or individuals that are listed on these sanctions lists can expose companies to substantial legal, financial, and reputational risks.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Iran, particularly in sectors like finance, oil and gas, and shipping, where the risks of dealing with sanctioned entities are higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to individuals or entities under international sanctions.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors like energy, defense, or any government-related sectors, as these areas are more likely to involve sanctioned entities.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to the Iranian government or military.
  • Investigate the ownership and control structures of entities engaged in large-scale or cross-border transactions, particularly when dealing with offshore entities or complex ownership structures that may mask Iranian connections.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals, entities, or assets linked to Iran’s nuclear, missile, or terrorism activities, as per the sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Iran, as the political landscape may lead to changes in the scope or nature of sanctions.
  • Monitor international developments related to the Joint Comprehensive Plan of Action (JCPOA) and any diplomatic negotiations that may result in shifts in Iran’s sanctions status.
  • Track changes in U.S. sanctions policies, particularly under different administrations, as these can significantly affect the business environment and compliance requirements related to Iran.

Risk Assessment:

High Risk – Iran presents a high risk in terms of international sanctions. The country is subject to comprehensive and complex sanctions imposed by the United Nations, the European Union, and the United States. These sanctions cover a broad range of sectors and individuals, with significant implications for businesses that engage in transactions or partnerships involving Iranian entities or individuals. Companies must exercise extreme caution and conduct rigorous due diligence to avoid exposure to sanctionable activities. Enhanced due diligence, regular screening, and ongoing monitoring of regulatory changes are essential to mitigate the high risk of non-compliance with international sanctions.

Iraq is not currently subject to comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. Iraq is a member of the United Nations and several international organizations, and it has generally aligned with international norms in recent years. While Iraq was subject to strict sanctions in the past, particularly during the 1990s under the regime of Saddam Hussein, these were lifted following the regime’s fall and the establishment of a new government. Since then, Iraq has worked to rebuild its economy and establish stronger diplomatic relations with the international community.

However, Iraq does face targeted sanctions, especially related to issues such as terrorism, corruption, and human rights abuses. These sanctions are typically directed at specific individuals, organizations, or entities connected to the Iraqi government or armed groups, particularly those linked to ISIS or other terrorist organizations.

Individuals/Entities under Targeted Sanctions:

• While Iraq as a country is not subject to comprehensive sanctions, specific individuals, entities, and groups within Iraq have been targeted by international sanctions, primarily related to terrorism and human rights violations.
• The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) maintains a list of individuals and entities associated with the Islamic State (ISIS), as well as political and military leaders accused of corruption, human rights abuses, or engaging in illicit activities.
• The United Nations also enforces sanctions on entities and individuals linked to terrorism or the financing of terrorist groups operating within Iraq.
• These sanctions may include asset freezes, travel bans, and restrictions on economic activities that could directly or indirectly involve businesses operating in Iraq.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Iraq, particularly in sectors such as oil, construction, and finance, where corruption or involvement in illicit activities might be higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or entities involved in terrorism, human rights violations, or corruption.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors related to government contracts, oil and gas, or reconstruction projects, which may involve entities with higher risks of corruption or illicit activities.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to the Iraqi government or military.
  • Investigate the ownership and control structures of entities engaged in large-scale or cross-border transactions, particularly when dealing with offshore entities or complex ownership structures that may be used to circumvent sanctions.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals, entities, or assets linked to terrorism, human rights abuses, or corruption, as per the sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Iraq and its political landscape, as changes could lead to new sanctions or regulatory adjustments.
  • Monitor developments in Iraq’s political environment, particularly any shifts in government policy, economic reforms, or international relations that could affect the country’s sanctions status.
  • Track changes to broader international sanctions regimes, especially those related to terrorism or corruption, which may impact Iraq indirectly.

Risk Assessment:

Medium Risk – Iraq presents a medium risk in terms of international sanctions. While the country is not under comprehensive sanctions, it is subject to targeted sanctions aimed at specific individuals, entities, and groups involved in terrorism or corruption. Businesses operating in Iraq should conduct thorough due diligence to ensure compliance with anti-money laundering (AML), counter-terrorism financing (CTF) regulations, and sanctions laws. Enhanced due diligence is especially important for high-value transactions or dealings in sectors with heightened risks, such as oil, construction, and government contracts. Regular screening against sanctions lists and monitoring of regulatory changes are crucial to mitigate potential risks.

Ireland is not subject to any comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. As a member of the European Union, the United Nations, and other international organizations, Ireland adheres to international laws and treaties, including sanctions regimes imposed by the EU and the UN. Ireland is recognized for its commitment to human rights, democracy, and the rule of law, which aligns with the broader policies of the EU and the United Nations.

Ireland’s foreign policy is largely shaped by EU regulations, and it follows EU sanctions concerning human rights abuses, corruption, terrorism, and other international issues. Ireland also implements UN sanctions, and while the country is not under sanctions itself, it must enforce sanctions imposed on other countries or individuals.

Individuals/Entities under Targeted Sanctions:

• Ireland does not have individuals or entities subject to comprehensive sanctions by international regulatory bodies.
• However, certain individuals and entities in Ireland may be subject to targeted sanctions, especially if they are linked to activities such as terrorism, money laundering, or other illicit activities that are sanctioned by the European Union, the United Nations, or the United States.
• The European Union and the United Nations impose sanctions on individuals or entities linked to terrorism, violations of international law, or other activities of concern. These sanctions may include asset freezes, travel bans, and trade restrictions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Ireland, particularly in sectors such as finance, technology, and natural resources, where the risks of money laundering or involvement in illicit activities might be higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to individuals or entities involved in sanctioned activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors like government contracts, finance, or sectors involving sensitive technologies, where the risks of corruption or illicit activities may be higher.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to governments or organizations in countries that are subject to sanctions.
  • Investigate the ownership and control structures of entities involved in large-scale transactions or cross-border activities, especially when dealing with offshore entities or complex ownership structures.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals, entities, or assets linked to terrorism, corruption, or other illicit activities, as per sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Ireland, the EU, or regions with international trade relations.
  • Monitor political and economic developments in Ireland, especially any shifts in government policy or changes to EU sanctions that may affect the country’s regulatory environment.
  • Track changes to broader international sanctions regimes, especially those related to financial crimes, terrorism, or human rights abuses, as these may indirectly affect businesses operating in or with Ireland.

Risk Assessment:

Low Risk – Ireland presents a low risk in terms of international sanctions. The country is not under any sanctions itself, and its political and economic environment is stable. Ireland’s adherence to EU and UN sanctions regulations means businesses operating in the country should have clear guidelines on compliance. While targeted sanctions may apply to specific individuals or entities, the general risk of encountering sanction-related issues is low. Businesses should ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations and conduct standard due diligence procedures, especially in sectors with higher risks of illicit activities. Regular monitoring of regulatory updates is advisable to ensure ongoing compliance with any future changes in sanctions or financial regulations.

Isle of Man is not subject to any comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a self-governing British Crown dependency, the Isle of Man maintains close ties with the United Kingdom but has its own legal and regulatory framework. While it is not an EU member state, it follows EU regulations as they apply to the UK and is also aligned with the UK's sanctions policies. Additionally, the Isle of Man enforces sanctions and complies with regulations that the UK applies, especially those related to terrorism, money laundering, human rights violations, and corruption.

The Isle of Man has robust anti-money laundering (AML) and counter-terrorism financing (CTF) measures in place, and it actively cooperates with international bodies such as the Financial Action Task Force (FATF) to ensure compliance with global standards. While the Isle of Man is not subject to sanctions itself, businesses must ensure that they do not engage in activities involving individuals or entities subject to international sanctions.

Individuals/Entities under Targeted Sanctions:

• The Isle of Man does not have any individuals or entities subject to comprehensive sanctions. However, it enforces targeted sanctions as imposed by the UK, the European Union, and the United Nations.
• These sanctions typically involve individuals or entities engaged in illicit activities such as terrorism, drug trafficking, human rights violations, or other activities prohibited by international law.
• The Isle of Man’s Financial Services Authority (FSA) and the UK’s HM Treasury maintain sanctions lists that include asset freezes, travel bans, and restrictions on individuals or entities linked to criminal or terrorist activities, which must be adhered to by businesses operating in the jurisdiction.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in the Isle of Man, particularly in sectors such as finance, insurance, and trust services, where there may be higher risks of illicit financial activities.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to individuals or entities involved in sanctioned activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors like finance or government contracts, where the risk of involvement in illicit activities or corruption may be higher.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with connections to high-risk countries or governments.
  • Investigate the ownership and control structures of entities involved in cross-border transactions or those with complex ownership arrangements that might be used to conceal illicit activities or connections to sanctioned parties.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UK, EU, UN, and other relevant authorities.
  • Ensure that business dealings do not involve individuals, entities, or assets linked to terrorism, corruption, or other illicit activities, as per the sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting the UK and the Isle of Man, as political or economic changes could lead to new financial regulations or the imposition of additional sanctions.
  • Monitor developments in the Isle of Man’s financial and regulatory landscape, particularly regarding AML, CTF regulations, and sanctions enforcement.
  • Track changes to broader international sanctions regimes, especially those targeting financial crimes, terrorism, or human rights abuses, as these could indirectly affect the Isle of Man’s regulatory environment.

Risk Assessment:

Low Risk – The Isle of Man presents a low risk in terms of international sanctions. The jurisdiction adheres to international regulatory standards and implements sanctions imposed by the UK, EU, and the UN. The business environment is stable, and there are no major concerns related to the imposition of comprehensive sanctions. However, businesses operating in or with the Isle of Man must remain diligent and conduct standard due diligence, particularly in sectors such as finance and insurance, where the risk of money laundering or illicit activities could be higher. Regular monitoring of regulatory changes and sanctions updates is recommended to ensure ongoing compliance.

Israel is not under comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. Israel is a member of the United Nations and has close diplomatic and trade relations with numerous countries globally, including many Western nations. Israel has a robust economy, advanced technological and defense industries, and is a key player in the Middle East. It is subject to certain international regulations and sanctions, particularly related to its activities in the Palestinian territories, but it is not broadly sanctioned by international organizations.

However, Israel faces some targeted sanctions, particularly from countries or organizations that disagree with its policies regarding Palestine and the Israeli-Palestinian conflict. Some countries have imposed sanctions on specific Israeli entities, individuals, or businesses that are involved in activities that are viewed as violations of international law, including settlement-building in occupied Palestinian territories. Israel, however, is not isolated from international trade, and these sanctions are generally limited to specific sectors or individuals.

Individuals/Entities under Targeted Sanctions:

• Israel itself is not subject to comprehensive international sanctions; however, specific individuals and entities in Israel are subject to targeted sanctions.
• The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) maintains sanctions against individuals, groups, and companies involved in human rights violations or terrorism. Certain Israeli companies or entities linked to settlement activities in Palestinian territories may face restrictions from various international bodies, including the EU or the UN.
• The United Nations, European Union, and other countries may impose sanctions or restrictions on entities linked to the Israeli military, defense industry, or companies involved in projects deemed illegal under international law.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Israel, particularly in sectors such as defense, construction, and technology, where the risk of involvement in controversial activities may be higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals or entities involved in controversial activities such as settlement construction or human rights violations.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors like defense, infrastructure, or projects in Palestinian territories, which may present a higher risk of being linked to controversial activities or international sanctions.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with connections to Israeli political figures or the Israeli military.
  • Investigate the ownership and control structures of entities involved in cross-border transactions, particularly those with complex ownership arrangements or ties to sanctioned entities in Israel or Palestinian territories.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities linked to activities or organizations subject to international sanctions, including those involved in settlement construction, human rights violations, or terrorism.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Israel, the Middle East, and other key players in the Israeli-Palestinian conflict.
  • Monitor developments in Israeli foreign and domestic policies, especially regarding settlements, international diplomacy, and relations with neighboring countries.
  • Track changes to broader international sanctions regimes, particularly those targeting human rights abuses, terrorism, or illegal settlements, as these may impact entities doing business with Israel.

Risk Assessment:

Medium Risk – Israel presents a medium risk in terms of international sanctions. While the country is not broadly sanctioned, certain individuals, companies, and sectors, particularly those linked to the Israeli military or settlement activities, may face targeted sanctions. Businesses operating in or with Israel should conduct thorough due diligence, particularly in sectors that might involve political or legal sensitivities. Enhanced due diligence is advisable for transactions or dealings with entities involved in Israeli settlements or projects in Palestinian territories. Continuous monitoring of political developments and regulatory changes related to Israel’s international relations is essential to mitigate potential risks from evolving sanctions.

Italy is not subject to comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. As a member of the European Union, the United Nations, and NATO, Italy adheres to international norms, including those related to sanctions and trade restrictions. The country is politically stable, economically developed, and a key player in global trade and diplomacy. Italy follows EU regulations and is part of the EU sanctions framework, implementing measures against countries, individuals, or entities involved in activities such as human rights violations, terrorism, or other breaches of international law.

Italy itself does not face any broad international sanctions, and its foreign policy aligns with EU and UN policies. However, businesses operating in Italy must be aware of the EU’s sanctions against certain countries or individuals, particularly in relation to geopolitical conflicts or economic misconduct.

Individuals/Entities under Targeted Sanctions:

• Italy does not have individuals or entities that are subject to broad international sanctions. However, specific individuals or entities within Italy may be subject to targeted sanctions based on their involvement in activities such as corruption, terrorism, or violations of international law.
• The European Union and the United Nations have imposed sanctions on individuals or entities in Italy that are linked to activities such as human rights violations, illegal trade, or support for terrorism. These sanctions may include asset freezes, travel bans, and trade restrictions.
• The United States Department of Treasury’s Office of Foreign Assets Control (OFAC) may also target Italian individuals or entities that are linked to illegal financial activities or violations of U.S. laws.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Italy, particularly in sectors such as finance, construction, and technology, where the risk of money laundering or illicit financial activities might be higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to individuals or entities involved in sanctioned activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors like government contracts, defense, or industries involving sensitive technologies, where the risks of corruption or illicit activities may be higher.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with ties to the Italian government, military, or entities involved in sectors prone to international sanctions.
  • Investigate the ownership and control structures of entities engaged in cross-border transactions, particularly those with offshore entities or complex ownership structures that could indicate higher risks of non-compliance.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals, entities, or assets linked to criminal activities, terrorism, corruption, or any other prohibited activities as per the sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Italy and the EU. Any changes in Italy’s international relations or EU sanctions policy could impact business operations.
  • Monitor political and economic developments in Italy, particularly any shifts in government policy, economic reforms, or potential changes to Italy’s relationships with countries that may be subject to sanctions.
  • Track changes to the broader international sanctions regimes, especially those affecting European countries or regions involved in conflicts or human rights issues.

Risk Assessment:

Low Risk – Italy presents a low risk in terms of international sanctions. The country is not subject to any comprehensive sanctions and adheres to international standards set by the European Union and the United Nations. While Italy implements sanctions against individuals and entities linked to criminal activities or violations of international law, these are typically targeted sanctions, and the general business environment remains stable. However, businesses operating in Italy should ensure compliance with EU regulations and conduct standard due diligence, particularly in sectors where the risk of illicit financial activities or non-compliance may be higher. Continuous monitoring of political and regulatory developments is recommended to stay informed of any potential changes in sanctions or compliance requirements.

Jamaica is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country enjoys diplomatic and trade relations with many nations and is an active member of international organizations, including the United Nations, the Organization of American States (OAS), and the Caribbean Community (CARICOM). Jamaica generally adheres to international standards and maintains a relatively stable political and economic environment. While the country is not under comprehensive sanctions, businesses should remain aware of potential risks that could arise in the future, particularly as international relations evolve or in response to illicit activities.

Jamaica’s government is committed to maintaining stability and economic growth, with a focus on improving the business climate. However, there are some concerns around corruption and criminal activities in certain sectors, which could increase risks in specific industries, such as banking, tourism, and real estate.

Individuals/Entities under Targeted Sanctions:

• Jamaica is not subject to broad international sanctions, but certain individuals or entities within the country may be targeted by sanctions due to involvement in activities such as drug trafficking, money laundering, or terrorism.
• The United States, through the U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC), has imposed sanctions on individuals and entities linked to organized crime and drug trafficking activities in Jamaica. These sanctions often involve asset freezes and travel bans.
• Additionally, Jamaica complies with UN and regional sanctions imposed on individuals or entities involved in activities that contravene international law or pose a threat to peace and security.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Jamaica, especially in high-risk sectors such as banking, construction, and real estate, where the potential for money laundering and corruption may be higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to individuals or entities involved in illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions or dealings with sectors related to government contracts, natural resources, or sensitive industries where the risks of corruption or illegal activities may be higher.
  • Scrutinize transactions involving politically exposed persons (PEPs), especially those with ties to the Jamaican government or law enforcement.
  • Investigate the ownership and control structures of entities involved in cross-border transactions or those with offshore links that could pose higher risks.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities that are linked to criminal activities, terrorism, or money laundering, as per the sanctions regulations.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting the Caribbean and Latin America, as changes in international relations could lead to new financial regulations or sanctions.
  • Monitor political developments in Jamaica, particularly those relating to governance, anti-corruption efforts, and international relations, which could affect the country's sanctions status.
  • Track changes in international sanctions regimes, especially those targeting transnational issues such as drug trafficking or organized crime, which may impact business operations in Jamaica.

Risk Assessment:

Medium Risk – Jamaica presents a medium risk in terms of international sanctions. While the country is not broadly sanctioned, targeted sanctions may be applied to individuals or entities involved in illicit activities such as drug trafficking, money laundering, or organized crime. The business environment in Jamaica is generally stable, but companies must exercise caution in sectors where corruption or criminal activity may be more prevalent. Regular due diligence and monitoring of political and regulatory developments are advisable to ensure compliance with any changes in sanctions or regulations.

Japan is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As one of the world’s largest economies, Japan maintains strong diplomatic and trade relationships with countries globally. It is a member of key international organizations, including the United Nations, the World Trade Organization (WTO), and the Organization for Economic Cooperation and Development (OECD). Japan follows international laws and regulations and plays an active role in enforcing UN sanctions, particularly those related to issues like North Korea's nuclear program, human rights violations, and counterterrorism efforts.

Although Japan itself is not under sanctions, businesses operating in or with Japan should be mindful of the international sanctions regimes, particularly those involving Japan’s foreign policy interests, such as sanctions related to North Korea, Russia, and Iran.

Individuals/Entities under Targeted Sanctions:

• Japan is not under comprehensive international sanctions, but certain individuals and entities in Japan may be subject to targeted sanctions.
• The Japanese government enforces United Nations Security Council (UNSC) sanctions, including those against North Korea, Russia, and Iran. These sanctions are generally aimed at curbing activities like nuclear proliferation, terrorism, or human rights violations.
• The U.S. Department of Treasury’s Office of Foreign Assets Control (OFAC) also imposes sanctions on certain individuals, companies, and financial institutions in Japan if they are linked to activities related to North Korea’s missile and nuclear programs, Iran’s nuclear activities, or other internationally prohibited actions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners, clients, and entities operating in Japan, particularly in sectors such as finance, technology, and defense, where the risk of engaging in activities linked to prohibited programs may be higher.
  • Review ownership structures of companies to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals, entities, or illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for high-value transactions, especially in sectors like technology, defense, and energy, where there may be higher risks related to export controls and dual-use technologies.
  • Scrutinize transactions involving politically exposed persons (PEPs), particularly those with links to Japan’s government, defense sectors, or entities engaged in international trade with countries under sanctions, such as North Korea and Iran.
  • Investigate the ownership and control structures of entities involved in cross-border transactions, particularly those with ties to sanctioned individuals, organizations, or countries.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals, entities, or assets linked to criminal activities, terrorism, or other prohibited activities as per international sanctions.
• Monitor for Regulatory Changes
  • Stay informed about updates to global sanctions regulations, particularly those affecting Japan, North Korea, Iran, and Russia.
  • Monitor changes in Japan’s foreign policy, particularly its approach to international sanctions, trade policies, and security-related issues that could affect business operations or the country's sanctions status.
  • Track changes in international sanctions regimes, especially those targeting countries like North Korea and Iran, which may have indirect impacts on business dealings in Japan.

Risk Assessment:

Low Risk – Japan presents a low risk in terms of international sanctions. The country is not subject to comprehensive sanctions and generally adheres to international norms and regulatory standards. However, businesses should remain vigilant and conduct standard due diligence, especially in sectors that may involve sensitive technologies or dealings with countries subject to international sanctions. Enhanced due diligence may be necessary for transactions that involve individuals or entities linked to sensitive sectors or geopolitical issues. Continuous monitoring of global sanctions and Japan’s foreign policy is advisable to stay ahead of any potential risks or regulatory changes.

Jordan is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country maintains stable relations with key international organizations and is recognized for its role as a peacebroker in the Middle East. While there are no broad sanctions imposed on Jordan, certain individuals or entities associated with regional conflicts, terrorism, or political issues may be subject to targeted sanctions, particularly by the United States and the European Union.

Individuals/Entities under Targeted Sanctions:

Certain individuals in Jordan, particularly those with ties to political, military, or terrorist activities, may be subject to targeted sanctions. These sanctions, which can include travel bans and asset freezes, are typically imposed by the United States, the European Union, or other authorities. They are often linked to concerns over regional security issues, counterterrorism efforts, or individuals involved in activities deemed harmful to peace and stability. These sanctions are generally focused on individuals rather than broad measures against the country as a whole.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Jordan, especially in sectors such as defense, government, and natural resources, which may have higher exposure to political or security risks.
  • Review the ownership structures of entities operating in Jordan to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are not linked to sanctioned individuals, entities, or sectors involved in corruption or regional instability.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as military procurement, government contracts, and infrastructure projects, where the potential for corruption, misallocation of resources, or ties to politically exposed persons (PEPs) may exist.
  • Scrutinize transactions involving individuals with connections to the Jordanian government, military, or those involved in sensitive regional matters such as counterterrorism and border security.
  • Investigate the ownership and control structures of entities involved in large or complex transactions, particularly those with potential links to government officials or military groups.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant sanctions authorities.
  • Ensure that business dealings are not made with individuals or entities linked to terrorism, corruption, or political repression, especially in sensitive sectors like defense or government procurement.
• Monitor for Regulatory Changes
  • Stay updated on political developments in Jordan, particularly in relation to its role in regional security and counterterrorism efforts.
  • Monitor any updates to international sanctions or human rights reports that may lead to further targeted sanctions or policy changes affecting individuals or entities within Jordan.
  • Track regulatory changes in Jordan, especially those related to anti-money laundering (AML), counter-terrorism financing (CTF), and financial transparency initiatives.

Risk Assessment:

Low Risk – Jordan presents a low risk in terms of international sanctions. The country is not under broad sanctions, but certain individuals and entities may be subject to targeted measures due to regional security issues or political concerns. Businesses should conduct standard due diligence and monitor sanctions lists regularly to avoid exposure to high-risk individuals or entities. Regular monitoring of political developments and regulatory changes will help mitigate potential risks.

Kazakhstan is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country has a stable political environment, strong economic growth, and maintains good relations with both Western and Eastern powers. While Kazakhstan itself is not under broad sanctions, certain individuals or entities within the country may be subject to targeted sanctions, particularly from the United States or the European Union, often due to concerns about corruption, human rights violations, or activities that undermine democratic governance.

Individuals/Entities under Targeted Sanctions:

Certain individuals and entities from Kazakhstan, particularly those involved in corruption, human rights abuses, or actions that undermine democracy, may be subject to targeted sanctions. These sanctions typically include travel bans, asset freezes, and restrictions on doing business with sanctioned entities. The U.S. Department of Treasury (OFAC) and the European Union have imposed sanctions on specific individuals linked to corruption, political repression, or activities that violate human rights. These sanctions are generally targeted rather than comprehensive measures against Kazakhstan as a whole.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Kazakhstan, especially in high-risk sectors such as government contracting, defense, and natural resources, which may have higher exposure to corruption and political risks.
  • Review the ownership structures of entities operating in Kazakhstan to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are not linked to sanctioned individuals, entities, or sectors involved in human rights abuses or corruption.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as defense procurement, government contracts, and large infrastructure projects, where the potential for corruption, misallocation of resources, or ties to politically exposed persons (PEPs) may be higher.
  • Scrutinize transactions involving individuals with connections to the Kazakh government, military, or individuals involved in activities that have raised international concerns over human rights or governance.
  • Investigate the ownership and control structures of entities involved in large or complex transactions, particularly those with potential links to high-ranking officials or state-owned enterprises.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities linked to corruption, human rights violations, or political repression, particularly in sectors like government procurement, defense, or energy.
• Monitor for Regulatory Changes
  • Stay updated on political developments in Kazakhstan, particularly those related to government policies on corruption, human rights, and democratic reforms.
  • Monitor any updates to international sanctions or human rights reports that may lead to further targeted sanctions or policy changes affecting individuals or entities within Kazakhstan.
  • Track regulatory changes within Kazakhstan, especially those related to anti-money laundering (AML), counter-terrorism financing (CTF), and financial transparency initiatives.

Risk Assessment:

Medium Risk – Kazakhstan presents a medium risk in terms of international sanctions. While the country itself is not under comprehensive sanctions, certain individuals and entities are subject to targeted sanctions due to concerns over corruption, human rights abuses, and governance issues. Businesses operating in Kazakhstan should conduct thorough due diligence, especially in sectors linked to government contracts, defense, and natural resources. Monitoring political developments and sanctions updates is critical to mitigate risks related to exposure to sanctioned individuals or entities.

Kenya is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country has a relatively stable political environment and is an important economic and diplomatic hub in East Africa. However, Kenya has faced some international scrutiny, particularly concerning governance, corruption, and human rights issues. While there are no broad sanctions imposed on Kenya, certain individuals and entities, especially those involved in corruption or human rights abuses, may be subject to targeted sanctions, primarily from the United States and the European Union.

Individuals/Entities under Targeted Sanctions:

Certain individuals and entities from Kenya, particularly those linked to corruption, human rights violations, or electoral violence, may be subject to targeted sanctions. These sanctions, often imposed by the United States, the European Union, or other international bodies, can include travel bans, asset freezes, and restrictions on business transactions. The sanctions are usually directed at individuals or organizations involved in activities such as electoral misconduct, human rights abuses, or large-scale corruption that undermines democratic governance and economic stability.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Kenya, especially in sectors like government contracting, natural resources, and infrastructure, where corruption risks may be higher.
  • Review the ownership structures of entities operating in Kenya to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are not linked to sanctioned individuals, entities, or sectors involved in corruption or human rights abuses.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors such as government contracts, infrastructure projects, and financial services, where there may be greater exposure to corruption, misallocation of resources, or ties to politically exposed persons (PEPs).
  • Scrutinize transactions involving individuals with connections to the Kenyan government, security forces, or those implicated in political or electoral violence and human rights violations.
  • Investigate the ownership and control structures of entities involved in large or complex transactions, particularly those with potential links to high-ranking government officials or politically influential individuals.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities linked to corruption, human rights violations, or political repression, especially in sectors such as government procurement, law enforcement, or energy.
• Monitor for Regulatory Changes
  • Stay updated on political developments in Kenya, particularly in relation to governance reforms, anti-corruption efforts, and the political landscape ahead of national elections.
  • Monitor any updates to international sanctions or human rights reports that may lead to further targeted sanctions or policy changes affecting individuals or entities within Kenya.
  • Track regulatory changes within Kenya, especially those related to anti-money laundering (AML), counter-terrorism financing (CTF), and financial transparency initiatives.

Risk Assessment:

Medium Risk – Kenya presents a medium risk in terms of international sanctions. While the country itself is not under comprehensive sanctions, certain individuals and entities are subject to targeted measures due to concerns about corruption, human rights violations, and political instability. Businesses operating in Kenya should conduct thorough due diligence, particularly in sectors that are vulnerable to corruption or political risks. Regular monitoring of political developments and sanctions lists is essential to mitigate exposure to high-risk individuals or entities.

Kuwait is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country is known for its stable political environment, robust economy, and strategic role in the Gulf region. It has a strong legal framework and is considered a reliable partner in the international community. However, Kuwait has faced some scrutiny, particularly regarding its role in regional geopolitics and concerns over human rights and labor conditions. While there are no broad sanctions imposed on Kuwait, certain individuals or entities within the country, especially those linked to terrorism financing or other illicit activities, may be subject to targeted sanctions, primarily from the United States and the United Nations.

Individuals/Entities under Targeted Sanctions:

Some individuals and entities from Kuwait may be subject to targeted sanctions, particularly those involved in terrorism financing, money laundering, or other illicit activities. The U.S. Department of Treasury (OFAC) and the United Nations have imposed sanctions on individuals or entities linked to terrorist organizations or activities that pose a threat to international peace and security. These sanctions can include asset freezes, travel bans, and restrictions on doing business with sanctioned entities. The Kuwaiti government has made efforts to address these concerns, particularly in terms of anti-money laundering (AML) and combating the financing of terrorism (CFT), but risks related to these areas remain.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Kuwait, especially in sectors such as finance, government contracting, and defense, where risks related to corruption, money laundering, and terrorism financing may be higher.
  • Review the ownership structures of entities operating in Kuwait to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals, entities, or sectors involved in illicit activities.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors such as government contracts, financial services, and cross-border trade, where the potential for money laundering, terrorism financing, or other illicit activities may be higher.
  • Scrutinize transactions involving individuals with connections to politically exposed persons (PEPs) or entities with links to sectors prone to corruption or terrorism financing.
  • Investigate the ownership and control structures of entities involved in large or complex transactions, particularly those with international links or ties to sensitive sectors like defense or banking.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities linked to terrorism, money laundering, or other criminal activities, especially in sensitive sectors like financial services or defense contracting.
• Monitor for Regulatory Changes
  • Stay updated on political and regulatory developments in Kuwait, particularly changes in government policy regarding anti-money laundering (AML), counter-terrorism financing (CTF), and other regulatory reforms.
  • Monitor any updates to international sanctions or counter-terrorism reports that may lead to further targeted sanctions or policy changes affecting individuals or entities within Kuwait.
  • Track changes in Kuwait’s legal and regulatory frameworks, especially those related to financial transparency, anti-corruption efforts, and the country’s obligations under international agreements.

Risk Assessment:

Medium Risk – Kuwait presents a medium risk in terms of international sanctions. While the country is not under comprehensive sanctions, certain individuals and entities are subject to targeted measures due to concerns related to money laundering, terrorism financing, and regional political issues. Businesses operating in Kuwait should conduct thorough due diligence, particularly in sectors vulnerable to illicit financial flows or political risks. Regular monitoring of sanctions lists, regulatory changes, and geopolitical developments is essential to mitigate risks related to exposure to sanctioned individuals or entities.

Kyrgyzstan is not currently subject to comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. The country enjoys relatively stable governance compared to some of its regional neighbors but has faced political instability in the past, particularly related to changes in government and protests. Kyrgyzstan’s political environment remains fluid, with ongoing concerns over corruption, weak rule of law, and human rights issues. While there are no broad sanctions imposed on Kyrgyzstan as a whole, certain individuals and entities within the country, particularly those associated with corruption or political violence, may be subject to targeted sanctions, mainly from the United States and the European Union.

Individuals/Entities under Targeted Sanctions:

Some individuals and entities from Kyrgyzstan, particularly those linked to corruption, human rights violations, or political repression, may be subject to targeted sanctions. The U.S. Department of Treasury (OFAC) and the European Union have imposed sanctions on individuals connected to these issues, particularly those involved in corrupt activities or undermining democratic processes. These sanctions typically include asset freezes, travel bans, and restrictions on business dealings. The Kyrgyz government has undertaken some efforts to combat corruption and improve governance, but challenges remain, and targeted measures against specific individuals may still be imposed in the future.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Kyrgyzstan, especially in sectors like government contracting, natural resources, and infrastructure, which may have higher exposure to corruption and political risks.
  • Review ownership structures of entities operating in Kyrgyzstan to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are not linked to sanctioned individuals, entities, or sectors involved in corruption or political violence.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as government contracts, defense procurement, and financial services, where the potential for corruption, fraud, or ties to politically exposed persons (PEPs) may be higher.
  • Scrutinize transactions involving individuals with connections to Kyrgyz government officials, military personnel, or those implicated in human rights abuses or political instability.
  • Investigate the ownership and control structures of entities involved in large or complex transactions, particularly those with links to government or state-owned enterprises.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities linked to corruption, human rights violations, or political violence, particularly in sensitive sectors like government procurement or infrastructure projects.
• Monitor for Regulatory Changes
  • Stay updated on political developments in Kyrgyzstan, especially in relation to ongoing efforts to tackle corruption, improve governance, and ensure human rights protections.
  • Monitor any updates to international sanctions, human rights reports, or political changes that could lead to further targeted sanctions or shifts in the regulatory environment in Kyrgyzstan.
  • Track changes in Kyrgyzstan’s regulatory frameworks, particularly those related to anti-money laundering (AML), counter-terrorism financing (CTF), and financial transparency initiatives.

Risk Assessment:

Medium Risk – Kyrgyzstan presents a medium risk in terms of international sanctions. While the country itself is not under broad sanctions, specific individuals and entities are subject to targeted measures due to ongoing concerns regarding corruption, human rights violations, and political instability. Businesses operating in Kyrgyzstan should conduct thorough due diligence, particularly in sectors linked to government contracts or other high-risk areas. Monitoring political developments, sanctions updates, and regulatory changes is crucial to mitigate exposure to high-risk individuals or entities.

Laos is not currently subject to comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. The country maintains a relatively stable political environment, governed by the Lao People's Revolutionary Party, which has been in power since 1975. Despite its political stability, Laos faces ongoing concerns related to human rights, lack of political freedoms, and limited press freedom. While Laos is not broadly sanctioned, the country has received international criticism for its human rights record, including its treatment of ethnic minorities, restrictions on freedom of speech, and its relationship with regional geopolitics. Some individuals and entities associated with corruption, human rights abuses, or links to criminal activities may be subject to targeted sanctions, particularly from the United States and other Western nations.

Individuals/Entities under Targeted Sanctions:

Some individuals and entities from Laos may be subject to targeted sanctions, especially those linked to corruption, human rights abuses, or political repression. The U.S. Department of Treasury (OFAC) and the European Union have imposed sanctions on individuals associated with serious human rights violations, illicit drug trafficking, or activities that undermine regional stability. These sanctions can include asset freezes, travel bans, and restrictions on business dealings. Laos has also been criticized for its involvement in drug production and trafficking, particularly the Golden Triangle region, where drug trade is a major concern.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Laos, particularly in sectors such as government contracting, natural resources, and infrastructure, which may have higher exposure to corruption and human rights risks.
  • Review the ownership structures of entities operating in Laos to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals, entities, or sectors involved in corruption or human rights violations.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as government contracts, infrastructure projects, and industries linked to the natural resources sector, where corruption and ties to politically exposed persons (PEPs) may be a concern.
  • Scrutinize transactions involving individuals or entities with connections to Laos’ political leadership, military, or organizations associated with drug trafficking or human rights abuses.
  • Investigate the ownership and control structures of entities involved in large or cross-border transactions, especially those linked to government-controlled entities or sectors with known corruption risks.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities linked to human rights violations, drug trafficking, or other illicit activities, particularly in sensitive sectors like natural resources, government contracts, or military-related industries.
• Monitor for Regulatory Changes
  • Stay updated on political developments in Laos, particularly in relation to changes in government policies, human rights, or international relations that could affect business operations.
  • Monitor updates to international sanctions or human rights reports that may lead to further targeted sanctions or policy changes affecting individuals or entities in Laos.
  • Track regulatory changes within Laos, particularly in areas related to anti-money laundering (AML), counter-terrorism financing (CTF), and anti-corruption initiatives.

Risk Assessment:

Medium Risk – Laos presents a medium risk in terms of international sanctions. While the country is not under broad sanctions, certain individuals and entities face targeted measures due to concerns over corruption, human rights abuses, and involvement in illicit activities such as drug trafficking. Businesses operating in Laos should conduct thorough due diligence, especially in sectors linked to government contracting, natural resources, and cross-border trade. Regular monitoring of sanctions lists, political developments, and regulatory changes is essential to mitigate risks related to exposure to high-risk individuals or entities.

Latvia is not subject to comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. As a member of both the European Union (EU) and NATO, Latvia adheres to international standards and obligations, including respecting human rights, democracy, and the rule of law. Latvia has a stable political environment, robust legal frameworks, and a commitment to international cooperation. However, like other EU member states, Latvia implements EU sanctions against other countries, entities, and individuals in response to human rights violations, political repression, or actions that threaten international peace and security. While Latvia itself is not under sanctions, it participates in global sanctions regimes and may enforce measures that align with the EU, U.S., or UN sanctions.

Individuals/Entities under Targeted Sanctions:

Latvia, through its participation in the EU and international organizations, enforces sanctions on individuals and entities linked to human rights abuses, terrorism, and corruption. These sanctions typically involve asset freezes, travel bans, and restrictions on business dealings. Latvia may also implement sanctions against entities involved in activities that threaten international security, such as those supporting the illegal annexation of territories or destabilizing actions in conflict regions. Latvia aligns with the EU’s Common Foreign and Security Policy, which periodically updates the sanctions lists based on changing geopolitical dynamics.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Latvia, especially in sectors such as finance, government contracting, and high-value assets, to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Review ownership structures of entities operating in Latvia to ensure they are transparent and legitimate, especially in sectors with higher risks of corruption or illicit activities.
  • Assess the source of funds and transactions to confirm they are not linked to any individuals or entities under sanctions or involved in activities like money laundering or corruption.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors such as finance, defense, and energy, where the potential for fraud, money laundering, or connections to politically exposed persons (PEPs) may be higher.
  • Scrutinize transactions involving individuals or entities with connections to politically sensitive sectors, especially those involved in government procurement, defense contracts, or industries with potential links to the Russian Federation or other sanctioned regimes.
  • Investigate the ownership and control structures of entities involved in large or cross-border transactions, particularly those linked to foreign governments or entities facing international sanctions.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and Latvia’s own enforcement of EU sanctions.
  • Ensure that business dealings are not conducted with individuals or entities that are subject to sanctions, particularly those related to terrorism, corruption, or actions undermining international peace and security.
• Monitor for Regulatory Changes
  • Stay updated on political developments in Latvia, especially in relation to its role within the EU and NATO and any changes in foreign policy that could affect business operations.
  • Monitor any updates or changes to sanctions lists from the EU, U.S., or UN that may affect Latvia or any of its trading partners.
  • Track changes in Latvia’s regulatory frameworks, particularly those related to anti-money laundering (AML), counter-terrorism financing (CTF), and financial transparency laws that may affect international business operations.

Risk Assessment:

Low Risk – Latvia presents a low risk in terms of international sanctions. The country enjoys a stable political environment, a strong rule of law, and is a member of key international organizations such as the EU and NATO. Businesses operating in Latvia are unlikely to face significant challenges related to international sanctions. However, it is essential for companies to maintain up-to-date screening of sanctions lists and stay informed about regulatory changes to ensure compliance with evolving global regulations.

Lebanon is not under comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. However, the country faces a complex geopolitical situation and has been subject to a variety of sanctions related to specific individuals, entities, and sectors. Lebanon’s political environment is influenced by the presence of multiple political factions, including groups with ties to Hezbollah, which is designated as a terrorist organization by the U.S. and several other countries. While Lebanon itself is not broadly sanctioned, several individuals, entities, and organizations linked to corruption, terrorism, or actions destabilizing the region are subject to targeted sanctions, particularly from the United States and other Western nations.

Individuals/Entities under Targeted Sanctions:

Certain individuals and entities in Lebanon are subject to targeted sanctions due to their involvement in activities such as terrorism, corruption, or human rights violations. The U.S. Department of Treasury (OFAC) and the European Union have imposed asset freezes, travel bans, and restrictions on business dealings with members of Hezbollah, senior Lebanese political figures, and business leaders linked to illicit activities. These sanctions are often tied to Hezbollah's role in regional conflicts, its involvement in criminal activities, and concerns regarding Lebanon’s stability. Additionally, entities involved in money laundering or violations of international financial regulations may also face targeted sanctions.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Lebanon, particularly in sectors such as finance, government contracting, and energy, which may have higher exposure to corruption and politically sensitive activities.
  • Review ownership structures of companies operating in Lebanon to ensure transparency and compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals, entities, or sectors with ties to terrorism or corruption.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as defense, infrastructure projects, and businesses with ties to the Lebanese government or Hezbollah, where risks of corruption, misallocation of resources, and links to politically exposed persons (PEPs) may be higher.
  • Scrutinize transactions involving individuals or entities with connections to Hezbollah, senior Lebanese political figures, or sectors tied to regional instability.
  • Investigate the ownership and control structures of entities involved in large or complex transactions, particularly those with potential links to sanctioned individuals or politically exposed figures in Lebanon.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not conducted with individuals or entities involved in terrorism, money laundering, or regional destabilization, particularly in sectors like government contracts, military procurement, and financial services.
• Monitor for Regulatory Changes
  • Stay updated on political and economic developments in Lebanon, particularly in relation to the ongoing challenges posed by Hezbollah and other political factions that could affect business operations.
  • Monitor updates to international sanctions or human rights reports that may lead to further targeted sanctions or policy changes affecting individuals or entities in Lebanon.
  • Track regulatory changes within Lebanon, especially those related to anti-money laundering (AML), counter-terrorism financing (CTF), and financial transparency initiatives.

Risk Assessment:

High Risk – Lebanon presents a high risk in terms of international sanctions. While the country itself is not broadly sanctioned, it is heavily influenced by political factions and entities, such as Hezbollah, which are subject to targeted sanctions. Businesses operating in Lebanon should exercise caution, particularly in sectors that are politically sensitive or linked to regional instability. Enhanced due diligence, continuous monitoring of sanctions lists, and staying informed about local and international developments are crucial to mitigating risks associated with corruption, terrorism, and potential exposure to sanctioned entities.

Lesotho is not currently subject to comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. The country has a stable political environment, with a constitutional monarchy and a multi-party system, and it generally adheres to international laws and standards. However, Lesotho has faced occasional scrutiny due to internal political challenges, including governance issues, corruption, and human rights concerns. Despite these challenges, there are no broad sanctions imposed on Lesotho as a whole, and it is not part of global sanctions regimes. The country is a member of various international organizations, including the Southern African Development Community (SADC) and the African Union (AU), and has committed to regional stability and economic development.

Individuals/Entities under Targeted Sanctions:

Lesotho has not been the subject of widespread international sanctions. However, certain individuals within the country, particularly those involved in corruption, human rights violations, or political repression, could potentially be subject to targeted measures by international bodies such as the United States or the European Union. These sanctions could include asset freezes, travel bans, and other restrictions imposed on individuals who threaten international peace and security or undermine democratic processes. For example, members of government or the military with links to corrupt practices or political violence may be sanctioned by countries or institutions that enforce global anti-corruption or human rights policies.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Lesotho, particularly in sectors such as mining, government contracting, and infrastructure, which may have exposure to corruption risks.
  • Review the ownership structures of entities operating in Lesotho to ensure transparency and compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to confirm that they are legitimate and not linked to individuals or entities involved in corruption or human rights abuses.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as government contracts, mining, and construction projects, where the potential for fraud, misallocation of resources, or connections to politically exposed persons (PEPs) may be higher.
  • Scrutinize transactions involving individuals with connections to Lesotho's government or military, particularly those with a history of political instability or corruption.
  • Investigate the ownership and control structures of entities involved in large transactions, especially those with potential links to individuals accused of corruption or human rights violations.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not conducted with individuals or entities linked to corruption, human rights violations, or political repression.
• Monitor for Regulatory Changes
  • Stay updated on political developments in Lesotho, particularly changes in government, leadership transitions, or any emerging concerns regarding political stability or human rights issues.
  • Monitor any updates to international sanctions lists or reports that may lead to further targeted sanctions or policy changes affecting individuals or entities within Lesotho.
  • Track regulatory changes within Lesotho, especially those related to anti-money laundering (AML), counter-terrorism financing (CTF), and financial transparency initiatives.

Risk Assessment:

Low Risk – Lesotho presents a low risk in terms of international sanctions. While the country faces occasional political and governance challenges, it is not under broad international sanctions, and businesses operating in Lesotho are unlikely to encounter significant challenges related to sanctions or compliance issues. However, companies should remain vigilant by conducting regular due diligence, monitoring political developments, and ensuring compliance with evolving global sanctions lists and regulatory frameworks.

Liberia is not currently subject to comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. However, the country has faced sanctions in the past, particularly during its civil war, when individuals, companies, and government officials linked to the conflict were sanctioned for their involvement in human rights abuses, arms trafficking, and violations of international law. While Liberia has made significant strides in post-conflict reconstruction and governance, it still faces challenges related to corruption, political instability, and economic development. These issues, however, have not led to broad sanctions being imposed on the country as a whole. Some individuals, particularly those involved in past conflicts or ongoing corruption, may still be subject to targeted sanctions.

Individuals/Entities under Targeted Sanctions:

Liberia is not subject to broad sanctions today, but certain individuals and entities associated with corruption, human rights violations, or political instability may still be subject to targeted sanctions. These sanctions typically involve asset freezes, travel bans, or restrictions on business dealings and are enforced by international bodies such as the United States (OFAC), the European Union, and the United Nations. These targeted measures often focus on individuals linked to the previous civil conflict, those involved in corruption or criminal activities, or those undermining democratic processes and the rule of law.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Liberia, especially in sectors such as mining, forestry, and government contracting, which are at higher risk for corruption and illicit activities.
  • Review the ownership structures of entities operating in Liberia to ensure transparency and compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to individuals or entities subject to sanctions for human rights abuses or corruption.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors such as mining, oil, and government contracts, where the risk of corruption, fraud, or links to politically exposed persons (PEPs) is higher.
  • Scrutinize transactions involving individuals with connections to Liberia’s government, military, or individuals accused of corruption, past conflict involvement, or human rights abuses.
  • Investigate the ownership and control structures of entities involved in large or complex transactions, especially those with potential links to sanctioned individuals or entities.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not conducted with individuals or entities involved in human rights violations, corruption, or political instability.
• Monitor for Regulatory Changes
  • Stay updated on political developments in Liberia, particularly changes in government, leadership transitions, or any emerging issues related to corruption or political unrest.
  • Monitor any updates to international sanctions lists or reports that may lead to further targeted sanctions or policy changes affecting individuals or entities within Liberia.
  • Track regulatory changes within Liberia, especially those related to anti-money laundering (AML), counter-terrorism financing (CTF), and financial transparency initiatives.

Risk Assessment:

Medium Risk – Liberia presents a medium risk in terms of international sanctions. While the country is not under comprehensive sanctions, the legacy of its civil conflict, along with ongoing issues of corruption and political instability, means that certain individuals and entities may be exposed to targeted sanctions. Businesses operating in Liberia should conduct thorough due diligence, particularly in sectors linked to government contracts or natural resource extraction, where the potential for corruption and illicit activities is higher. Monitoring political developments and updates to international sanctions is crucial to mitigate risks related to human rights abuses, corruption, and potential exposure to sanctioned individuals.

Libya has been subject to various international sanctions over the years, primarily due to its past regime under Muammar Gaddafi, which was associated with human rights violations, terrorism, and violations of international law. Since the overthrow of Gaddafi in 2011, the country has faced political instability, armed conflict, and the fragmentation of authority, which have resulted in continued sanctions from major regulatory bodies such as the United Nations, the European Union, and the United States. These sanctions have focused on individuals, entities, and sectors linked to human rights abuses, terrorism, the Libyan National Army (LNA), and the country's ongoing civil conflict.

Despite efforts to stabilize and rebuild the country, Libya remains under significant international scrutiny, with targeted sanctions still in place against certain individuals, militias, and entities tied to terrorism, illegal oil exports, and human rights violations.

Individuals/Entities under Targeted Sanctions:

Libya is subject to UN Security Council sanctions, EU sanctions, and U.S. sanctions, which primarily target individuals and entities involved in violations of human rights, the destabilization of the country, and activities that undermine the peace process. These measures include asset freezes, travel bans, and arms embargoes. The sanctions lists include:

• Individuals with ties to armed groups, militias, or factions involved in the Libyan conflict.
• Libyan leaders and officials associated with the previous Gaddafi regime.
• Entities linked to illegal oil exports and trafficking in arms or mercenaries.
• Individuals or entities accused of corruption or violations of international humanitarian law.

These sanctions are designed to pressure those involved in destabilizing the country, prevent the flow of funds to armed groups, and encourage a peaceful resolution to the conflict.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Libya, especially in high-risk sectors such as oil, construction, and government contracting, which may have links to militias or corrupt practices.
  • Review ownership structures of entities operating in Libya to ensure transparency and compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to individuals or entities subject to UN, EU, or U.S. sanctions for terrorism, human rights abuses, or corruption.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors such as oil extraction, arms trading, and government contracts, where there is a higher risk of involvement with sanctioned individuals or groups.
  • Scrutinize transactions involving individuals with connections to Libyan political factions, militias, or entities accused of human rights violations or destabilizing the country.
  • Investigate the ownership and control structures of entities involved in large or complex transactions, especially those with potential links to entities or individuals named in sanctions lists.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not conducted with individuals or entities involved in illegal oil exports, human rights abuses, or terrorism, which are ongoing concerns in Libya.
  • Ensure that all business transactions do not violate arms embargoes or involve sanctioned parties.
• Monitor for Regulatory Changes
  • Stay updated on political and military developments in Libya, particularly regarding the conflict, changes in the government, and any peace process or ceasefire negotiations.
  • Monitor any updates to international sanctions, including any new sanctions or modifications to existing measures, which could affect business operations in Libya.
  • Track changes in Libya’s financial regulations, including anti-money laundering (AML) and counter-terrorism financing (CTF) laws, as well as broader regulatory efforts to combat illicit activities.

Risk Assessment:

High Risk – Libya presents a high risk in terms of international sanctions due to the ongoing civil conflict, political instability, and the presence of armed militias and human rights abuses. Although the country is not under comprehensive sanctions, significant targeted sanctions remain in place against individuals, entities, and sectors that contribute to the destabilization of the country. Businesses operating in or with Libya should exercise extreme caution, conduct thorough due diligence, and ensure compliance with international sanctions. Regular monitoring of political developments and updates to sanctions lists is essential to mitigate risks related to conflict, corruption, and involvement with sanctioned parties.

Liechtenstein is not currently subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. The country is known for its strong legal framework, political stability, and adherence to international laws and regulations. As a member of the European Economic Area (EEA) and the Schengen Area, Liechtenstein aligns itself with international standards, including those related to anti-money laundering (AML), counter-terrorism financing (CTF), and the enforcement of global sanctions.

Liechtenstein does, however, implement sanctions in line with the European Union and the United Nations Security Council, meaning it enforces EU and UN sanctions against specific countries, individuals, and entities. The country also has its own regulatory measures aimed at preventing financial crimes such as money laundering and tax evasion, given its status as a financial hub.

Individuals/Entities under Targeted Sanctions:

Liechtenstein enforces international sanctions as part of its commitment to global security and stability. While the country itself is not under sanctions, it enforces restrictions on individuals and entities that are subject to UN Security Council resolutions, EU sanctions, and those issued by other international bodies. These targeted sanctions may include asset freezes, travel bans, and restrictions on doing business with individuals or entities that are involved in activities such as terrorism, human rights abuses, and illegal trade.

Individuals and entities that are subject to targeted sanctions are typically involved in:

• Terrorism or support for terrorist organizations.
• Human rights violations or violations of international humanitarian law.
• Corruption, money laundering, or illegal activities that undermine global peace and security.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Liechtenstein, especially in the financial and banking sectors, where the risk of illicit activities may be higher due to the country’s financial hub status.
  • Review ownership structures of companies operating in Liechtenstein to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals, entities, or activities related to terrorism or human rights violations.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors such as banking, wealth management, and international trade, where there may be a higher risk of exposure to money laundering, tax evasion, or terrorism financing.
  • Scrutinize transactions involving individuals with connections to politically exposed persons (PEPs) or individuals/entities involved in activities subject to UN or EU sanctions.
  • Investigate ownership and control structures of entities involved in complex or high-value transactions, particularly those with cross-border elements that may involve sanctioned individuals or entities.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities subject to international sanctions related to terrorism, human rights violations, corruption, or other illicit activities.
  • Conduct thorough screening to ensure compliance with EU and UN sanctions regulations that Liechtenstein enforces.
• Monitor for Regulatory Changes
  • Stay updated on political and economic developments in Liechtenstein, particularly any changes to its financial regulations, such as updates to anti-money laundering (AML) or counter-terrorism financing (CTF) laws.
  • Monitor any updates to international sanctions lists that may affect business operations in Liechtenstein or its role as a financial center.
  • Track changes to Liechtenstein's adherence to international financial standards, particularly regarding sanctions, tax evasion, and anti-money laundering regulations.

Risk Assessment:

Low Risk – Liechtenstein presents a low risk in terms of international sanctions. The country is politically stable, adheres to international regulatory standards, and has a robust legal framework for combating financial crimes. It is highly committed to enforcing international sanctions, especially those imposed by the EU and the UN, making it a reliable business environment for compliance purposes. However, businesses operating in Liechtenstein, especially those in the financial sector, should remain vigilant and regularly monitor changes to sanctions lists and regulatory frameworks to ensure compliance with evolving global standards.

Lithuania is not subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a member of the European Union, NATO, and other international organizations, Lithuania adheres to EU regulations and international laws, including those related to sanctions enforcement. The country enjoys a stable political environment, a robust legal system, and a commitment to democracy, human rights, and the rule of law.

While Lithuania itself is not under sanctions, it enforces EU sanctions, which may target individuals, entities, or sectors in countries that are deemed to violate international laws, engage in terrorism, or pose a threat to global peace and security. Lithuania is fully aligned with the EU’s foreign policy, including its sanctions regime, and actively participates in international efforts to combat corruption, human rights violations, and terrorism.

Individuals/Entities under Targeted Sanctions:

Lithuania implements EU sanctions and other international measures, which may target individuals, entities, and organizations involved in activities such as terrorism, human rights abuses, illegal trade, and corruption. These sanctions typically include asset freezes, travel bans, and restrictions on economic activities. Sanctions are usually applied to:

• Individuals and entities involved in violations of international humanitarian law.
• Actors supporting terrorism or engaged in destabilizing actions.
• Persons or entities implicated in corruption, illegal arms trading, or human trafficking.

Lithuania adheres to EU regulations regarding the implementation of these sanctions and plays an active role in enforcing them within its jurisdiction.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Lithuania, especially in sectors such as finance, energy, and government contracting, which may have higher exposure to corruption or illicit financial activities.
  • Review the ownership structures of companies operating in Lithuania to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to individuals or entities subject to EU or international sanctions.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as finance, energy, and defense, where there may be a higher risk of links to politically exposed persons (PEPs) or parties subject to EU sanctions.
  • Scrutinize transactions involving individuals with connections to government officials, military, or entities associated with human rights violations, terrorism, or corruption.
  • Investigate the ownership and control structures of entities involved in large or complex transactions, particularly those with cross-border elements that may involve sanctioned individuals or entities.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings do not involve individuals or entities subject to EU sanctions, particularly those linked to corruption, human rights abuses, or terrorism.
  • Regularly update screening procedures to account for changes in the EU sanctions list, as well as those from international bodies.
• Monitor for Regulatory Changes
  • Stay updated on political developments in Lithuania, particularly any changes in government policies, economic sanctions, or international relations that could impact business operations.
  • Monitor updates to EU sanctions or the imposition of new sanctions that could affect entities within Lithuania.
  • Track regulatory changes within Lithuania, especially those related to financial transparency, anti-money laundering (AML), counter-terrorism financing (CTF) laws, and compliance with international sanctions.

Risk Assessment:

Low Risk – Lithuania presents a low risk in terms of international sanctions. As a member of the European Union, Lithuania adheres to stringent EU regulations, including the enforcement of sanctions against individuals and entities engaged in activities that threaten international peace and security. The country’s stable political environment, commitment to the rule of law, and strong legal framework make it a low-risk jurisdiction for businesses seeking to comply with global sanctions regimes. However, businesses should remain vigilant and continue to monitor for any changes in EU sanctions lists and regulatory frameworks to ensure ongoing compliance.

Luxembourg is not subject to comprehensive international sanctions by major regulatory bodies such as the United Nations, the European Union, or the United States. As a member of the European Union, the United Nations, and other key international organizations, Luxembourg adheres to international laws and regulations, including those related to sanctions enforcement. The country is known for its political stability, strong financial sector, and commitment to human rights, the rule of law, and democratic principles.

Although Luxembourg is not under sanctions, it fully implements EU sanctions and other international measures, which may target individuals, entities, or sectors linked to terrorism, human rights violations, corruption, or actions threatening international peace and security. Luxembourg plays an active role in enforcing these sanctions, in line with its commitments to global security and stability.

Individuals/Entities under Targeted Sanctions:

Luxembourg implements EU and UN sanctions, which target specific individuals, entities, and organizations involved in illegal activities, including terrorism, corruption, and human rights abuses. These sanctions typically involve asset freezes, travel bans, and restrictions on business dealings. Individuals and entities subject to these measures may be involved in:

• Human rights violations or violations of international law.
• Support for terrorism or other destabilizing activities.
• Corruption, money laundering, and illegal trade.

Luxembourg’s financial and banking systems are closely regulated to prevent money laundering and financing of terrorism, ensuring that sanctioned individuals and entities are not able to operate within the country’s financial infrastructure.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Luxembourg, particularly in sectors such as finance, investment, and government contracting, where the risk of exposure to illicit activities or sanctioned individuals is higher.
  • Review ownership structures of companies operating in Luxembourg to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure that they are not linked to sanctioned individuals, entities, or sectors involved in corruption or human rights violations.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors such as financial services, defense, and energy, where the risk of corruption, money laundering, or terrorism financing may be greater.
  • Scrutinize transactions involving individuals or entities with connections to politically exposed persons (PEPs), or those linked to countries or sectors that have been subject to EU or UN sanctions.
  • Investigate the ownership and control structures of entities involved in complex or cross-border transactions to ensure compliance with sanctions and to identify any potential links to sanctioned individuals or entities.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that no business dealings are conducted with individuals or entities that are subject to EU, UN, or U.S. sanctions related to terrorism, human rights abuses, or corruption.
  • Keep screening practices up-to-date with changes in sanctions lists from the EU, UN, and other bodies.
• Monitor for Regulatory Changes
  • Stay updated on political and economic developments in Luxembourg, particularly any changes in regulations that could affect business operations or financial transactions.
  • Monitor updates to EU sanctions lists or new sanctions that could impact business dealings with entities in Luxembourg.
  • Track any regulatory changes in Luxembourg related to anti-money laundering (AML), counter-terrorism financing (CTF), and financial transparency initiatives.

Risk Assessment:

Low Risk – Luxembourg presents a low risk in terms of international sanctions. As a member of the European Union and an active participant in global security and financial stability, Luxembourg adheres to stringent international sanctions and regulatory measures. The country’s stable political environment, strong financial sector, and commitment to the rule of law contribute to a low-risk environment for businesses seeking to ensure compliance with global sanctions regimes. However, businesses should remain vigilant and monitor for any changes in EU sanctions or regulatory frameworks that may affect their operations in Luxembourg.

Macao is not currently subject to comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. As a Special Administrative Region (SAR) of China, Macao follows the "one country, two systems" principle, which allows it to maintain a high degree of autonomy, particularly in areas such as economic policy, finance, and trade. However, Macao aligns itself with Chinese foreign policy and international obligations, including the enforcement of UN sanctions and other international measures.

Macao has a stable political environment and a strong legal framework, with its economy driven by tourism, gaming, and financial services. Although Macao itself is not under international sanctions, the region does adhere to Chinese regulations on sanctions enforcement, especially concerning issues such as human rights violations, terrorism, and the proliferation of weapons of mass destruction. Macao is also aligned with international efforts to combat money laundering and the financing of terrorism.

Individuals/Entities under Targeted Sanctions:

While Macao is not directly subject to international sanctions, certain individuals and entities based in or linked to Macao may be subject to targeted sanctions imposed by the United Nations, the European Union, or the United States. These sanctions typically focus on individuals or entities involved in:

• Human rights abuses or violations of international law.
• Support for terrorism or other destabilizing activities.
• Proliferation of weapons of mass destruction or illegal trade.

In particular, businesses in Macao may need to be cautious when dealing with financial institutions, individuals, or entities that have connections to sanctioned parties or that are operating in sectors at high risk of exposure to illegal activities, including money laundering.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Macao, particularly in sectors such as finance, gaming, and real estate, which may have higher exposure to corruption and illicit activities.
  • Review ownership structures of entities operating in Macao to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to individuals or entities subject to international sanctions.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as gaming, real estate, and finance, where there may be a higher risk of illicit financial flows or ties to politically exposed persons (PEPs).
  • Scrutinize transactions involving individuals or entities linked to the Chinese government or individuals from regions under sanctions.
  • Investigate the ownership and control structures of entities involved in complex or cross-border transactions to identify potential links to sanctioned entities or individuals.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities linked to corruption, terrorism, human rights abuses, or the proliferation of weapons of mass destruction.
  • Update screening procedures to reflect changes in global sanctions lists and to account for any new sanctions targeting entities or individuals in Macao or China.
• Monitor for Regulatory Changes
  • Stay updated on political and economic developments in Macao, particularly in relation to changes in government policy, international relations, or economic activities that could impact business operations.
  • Monitor updates to Chinese foreign policy or any sanctions imposed by the UN, EU, or U.S. that may affect business dealings involving Macao.
  • Track regulatory changes within Macao related to financial transparency, anti-money laundering (AML), and counter-terrorism financing (CTF) laws.

Risk Assessment:

Medium Risk – Macao presents a medium risk in terms of international sanctions. While it is not directly subject to sanctions, the region’s strong economic and financial ties with China and its high exposure to sectors such as gaming, finance, and real estate, which can have connections to illicit financial flows, raise potential risks. Businesses operating in Macao should be cautious, particularly when dealing with cross-border transactions, individuals or entities linked to politically sensitive regions, and high-risk sectors. Maintaining thorough due diligence, regularly screening against sanctions lists, and monitoring for regulatory changes will be essential to mitigate risks related to sanctions violations, money laundering, and financial crimes.

Madagascar is not currently subject to comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. The country has faced periods of political instability, particularly following the 2009 coup, which led to the suspension of Madagascar from the African Union and other international bodies for a period. However, in recent years, Madagascar has made efforts to stabilize its political environment and improve its relations with the international community.

While Madagascar itself is not under broad international sanctions, the country has faced targeted measures from the United States and the European Union in the past, especially due to concerns about governance issues, human rights, and political repression. Some individuals, primarily from the political elite, may be subject to targeted sanctions, including asset freezes and travel bans.

Individuals/Entities under Targeted Sanctions:

Certain individuals from Madagascar, particularly those associated with the 2009 coup and subsequent governance issues, may be subject to targeted sanctions, including asset freezes and travel bans imposed by the United States and the European Union. These sanctions are typically imposed due to concerns over:

• Political instability and repression.
• Human rights abuses, including restrictions on political opposition.
• Corruption and lack of transparency in government operations.

While Madagascar is not subject to broad sanctions, businesses should be aware of these targeted sanctions when operating in sectors such as government contracting, finance, or natural resources, where the risk of exposure to politically connected individuals is higher.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Madagascar, particularly in sectors such as mining, government contracting, and agriculture, which may be more exposed to corruption or links with politically exposed persons (PEPs).
  • Review ownership structures of companies operating in Madagascar to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not connected to sanctioned individuals, entities, or sectors involved in human rights violations or political instability.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors such as natural resources, government procurement, and infrastructure, where corruption or misallocation of resources may be more prevalent.
  • Scrutinize transactions involving individuals or entities linked to Madagascar’s political elite, military, or those with a history of involvement in political repression or human rights abuses.
  • Investigate the ownership and control structures of entities involved in large or complex transactions, particularly those with international links or involvement in sensitive sectors.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities that are subject to sanctions related to corruption, political instability, or human rights violations.
  • Keep screening procedures up-to-date with changes in sanctions lists from the EU, UN, and other bodies.
• Monitor for Regulatory Changes
  • Stay updated on political and economic developments in Madagascar, particularly in relation to changes in government leadership, civil unrest, or reforms that may impact business operations.
  • Monitor updates to international sanctions or human rights reports that may lead to further targeted sanctions or policy changes affecting individuals or entities within Madagascar.
  • Track regulatory changes within Madagascar, especially those related to anti-money laundering (AML), counter-terrorism financing (CTF), and financial transparency initiatives.

Risk Assessment:

Medium Risk – Madagascar presents a medium risk in terms of international sanctions. While the country is not under comprehensive sanctions, certain individuals and entities may be subject to targeted sanctions due to concerns over political instability, human rights abuses, and corruption. Businesses operating in Madagascar should exercise thorough due diligence, particularly in sectors that are at higher risk of exposure to corruption or political instability. Regular monitoring of sanctions updates and political developments is essential to mitigate risks related to business dealings with sanctioned individuals or entities.

Malawi is not currently subject to comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. The country has enjoyed relative political stability and economic growth in recent years, especially after the peaceful transition of power following democratic elections. Malawi is a member of several international organizations, including the United Nations, the African Union, and the Southern African Development Community (SADC), and has made efforts to improve governance and economic reforms.

However, while Malawi is not under broad sanctions, the country has faced some international scrutiny, particularly in areas such as corruption, governance, and human rights. These issues have led to occasional targeted sanctions on individuals and entities within Malawi, particularly those involved in corruption, abuse of power, or human rights violations.

Individuals/Entities under Targeted Sanctions:

Some individuals from Malawi, particularly those involved in significant corruption scandals, human rights violations, or undermining democratic processes, may be subject to targeted sanctions. These sanctions could include asset freezes and travel bans, primarily imposed by the United States and other Western nations. For example, individuals involved in the 2013 "Cashgate" scandal, where public funds were embezzled, may be subject to such sanctions.

The country's financial and political sectors are under scrutiny for governance challenges, and businesses must be aware of the risk of dealing with individuals or entities that may be connected to sanctioned parties or involved in corruption.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Malawi, especially in sectors like government contracting, agriculture, and mining, which may have higher exposure to corruption or links to politically exposed persons (PEPs).
  • Review ownership structures of companies operating in Malawi to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not connected to any individuals or entities subject to sanctions or involved in corruption.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors such as government procurement, natural resources, and infrastructure, where the risk of corruption, fraud, or misallocation of resources may be higher.
  • Scrutinize transactions involving individuals or entities with close ties to the Malawian government, particularly those associated with corruption scandals or politically sensitive sectors.
  • Investigate ownership and control structures of entities involved in large or complex transactions, particularly those with potential links to individuals or organizations that are part of ongoing corruption investigations.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities linked to corruption, political repression, or human rights violations, particularly in sectors like government contracts and public procurement.
  • Maintain up-to-date screening procedures to reflect changes in global sanctions lists and monitor for the addition of any new names related to Malawian individuals or entities.
• Monitor for Regulatory Changes
  • Stay updated on political and economic developments in Malawi, particularly in relation to governance reforms, anti-corruption efforts, and changes in leadership.
  • Monitor any updates from international bodies or changes in Malawian domestic laws, such as anti-money laundering (AML), counter-terrorism financing (CTF), and financial transparency regulations.
  • Track any changes in Malawi’s relationship with the international community, including adjustments to trade agreements, foreign investment policies, or diplomatic relations that may affect business operations.

Risk Assessment:

Medium Risk – Malawi presents a medium risk in terms of international sanctions. Although the country is not under comprehensive sanctions, there are concerns related to governance, corruption, and human rights violations. Certain individuals and entities in Malawi may be subject to targeted sanctions, particularly those linked to political corruption or abuses of power. Businesses operating in Malawi should conduct thorough due diligence, especially in high-risk sectors such as government procurement, agriculture, and mining. Regular monitoring of sanctions updates and political developments will be crucial to mitigate the risks associated with corruption and potential exposure to sanctioned individuals or entities.

Malaysia is not currently subject to comprehensive international sanctions imposed by major regulatory bodies such as the United Nations, the European Union, or the United States. The country has a robust economy, a stable political environment, and is an active member of various international organizations, including the United Nations, the Association of Southeast Asian Nations (ASEAN), and the World Trade Organization (WTO). Malaysia is also known for its commitment to economic development and regional security.

While Malaysia itself is not under broad sanctions, the country has faced occasional scrutiny over issues such as corruption, human rights, and political freedoms. At times, certain individuals or entities in Malaysia have been subject to targeted sanctions, particularly due to concerns related to human rights violations, corruption, or issues related to democratic governance.

Individuals/Entities under Targeted Sanctions:

Some individuals or entities in Malaysia, particularly those linked to corruption or human rights abuses, may be subject to targeted sanctions. For example, the United States and the European Union have imposed targeted measures, including asset freezes and travel bans, on individuals involved in corruption scandals, such as those connected to the 1MDB (1Malaysia Development Berhad) scandal. These sanctions are typically imposed in response to actions such as embezzlement of state funds, human rights abuses, or undermining democratic processes.

Although Malaysia is not subject to broad sanctions, businesses should be aware of the risk of exposure to individuals or entities connected to corruption or other unlawful activities.

Recommendations:

• Standard Due Diligence
  • Verify the identities of business partners and customers based in Malaysia, especially in sectors such as finance, government contracting, and real estate, which may have higher exposure to corruption and politically exposed persons (PEPs).
  • Review ownership structures of companies operating in Malaysia to ensure compliance with anti-money laundering (AML) and counter-terrorism financing (CTF) regulations.
  • Assess the source of funds and transactions to ensure they are legitimate and not linked to sanctioned individuals, entities, or sectors involved in corruption or human rights violations.
• Enhanced Due Diligence
  • Apply enhanced due diligence for transactions involving high-risk sectors, such as government procurement, banking, and real estate, where the potential for corruption, fraud, or other illicit activities may be higher.
  • Scrutinize transactions involving individuals or entities connected to Malaysia’s political elite, particularly those linked to corruption scandals or other controversial dealings.
  • Investigate ownership and control structures of entities involved in large or complex transactions, especially those with potential connections to government officials or politically exposed individuals.
• Screen Against Sanctions Lists
  • Regularly screen all clients, transactions, and business partners against global sanctions lists, including those from the UN, EU, U.S. Department of Treasury (OFAC), and other relevant authorities.
  • Ensure that business dealings are not made with individuals or entities that are subject to sanctions for reasons such as corruption, human rights abuses, or illegal activities.
  • Maintain an up-to-date screening process to reflect changes in sanctions lists and ensure compliance with any new restrictions that may be imposed on Malaysian entities or individuals.
• Monitor for Regulatory Changes
  • Stay updated on political and economic developments in Malaysia, particularly in relation to governance reforms, anti-corruption efforts, and changes in leadership or policy that may affect business operations.
  • Monitor any updates from international bodies or changes in Malaysian domestic laws, such as anti-money laundering (AML), counter-terrorism financing (CTF), and financial transparency regulations.
  • Track regulatory changes related to Malaysia’s foreign policy, particularly its relationships with major trade partners, as these could affect business operations or compliance requirements.

Risk Assessment:

Medium Risk – Malaysia presents a medium risk in terms of international sanctions. The country is not under comprehensive sanctions, but there are concerns related to corruption, political governance, and human rights. Specific individuals and entities in Malaysia, especially those involved in high-profile corruption cases, may be subject to targeted sanctions. Businesses operating in Malaysia should conduct thorough due diligence, particularly in sectors with higher risks of corruption or connections to politically exposed persons. Ongoing monitoring of sanctions lists and political developments is essential to mitigate the risks associated with exposure to sanctioned individuals or entities.