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Sanctions and AML

Overview

Preventive frameworks for AML, sanctions and regulatory compliance, built to satisfy regulators, banks, funders and auditors.

Four regimes matter to most of our clients, the EU, Switzerland, the UK and the reach of US rules, and they are similar without being identical. The cost of treating them as one, or of treating any of them casually, arrives through blocked payments, failed onboarding and supervisory findings long before any enforcement.

We design and test the preventive layer: risk assessments, AML frameworks including the Swiss regime as it extends to specified advisory activities on 1 October 2026, sanctions compliance across all four regimes with ownership-and-control analysis and contract remediation, and the country-risk and counterparty diligence that decides whether business proceeds. Our work is transactional and regulatory counsel: we build and defend frameworks; we do not act in criminal or administrative-criminal proceedings or before criminal courts, and where a report leads there we work alongside defence counsel.

The recurring theme of our published analysis applies to the practice itself: regulators, funders and banks test the same facts through different lenses, so the efficient answer is one evidence file, built to the most demanding applicable standard, with the points where the regimes conflict, such as the EU Blocking Statute, addressed on their own terms.

The stack we build, bottom up: 1 · RISK ASSESSMENT Documented, business-specific, refreshed on a cycle: the load-bearing wall every regime asks for first 2 · POLICIES AND CONTROLS KYC and due diligence design, sanctions screening logic, contract clauses, escalation routes with named owners 3 · OPERATIONS Screening and monitoring that runs, calibrated and documented; training; reporting readiness 4 · EVIDENCE One file, one version of the truth, built for regulators, banks, funders and auditors alike

Compliance as architecture: each layer rests on the one below it.

Follow the frameworks behind this practice in our AML/Compliance Hub.

How we help

AML frameworks

  • Business-specific risk assessments that carry the whole framework
  • KYC, CDD and beneficial-ownership identification and verification, with register consultation and any filing duties mapped in
  • Swiss GwG compliance, including the new adviser duties from 1 October 2026, and beneficial-ownership filings under the separate Transparency of Legal Persons Act (TJPG), with their transition periods
  • Readiness for the EU's 2027 single rulebook, planned from the current law
  • Art-market businesses: UK art market participant registration and due diligence, EU obliged-entity duties and the Swiss cash-dealer rules, with our Art Law practice

Sanctions compliance

  • Multi-regime screening design: EU, Swiss, UK and US lists, on the right update cadence
  • Ownership-and-control analysis for counterparties and supply chains
  • Contract programmes: no-re-export clauses, sanctions representations, termination rights
  • Third-country subsidiary governance under best-efforts obligations

Counterparty and country risk

  • Country-risk models pegged to the FATF, EU and UK lists on their real timetables
  • Enhanced due diligence design for high-risk relationships
  • Onboarding files built to withstand bank and funder review
  • Private clients and family offices: the evidence a bank, dealer or counterparty is required to request, prepared before the transaction
  • De-risking responses: documented positions when banks or partners hesitate

Investigations and remediation

  • Responding to regulator and bank information requests
  • Internal investigations into sanctions and AML incidents, scoped with counsel privilege in mind and with defence counsel where a matter turns criminal
  • Mandatory and voluntary reporting to SECO, OFSI and OFAC, and licence applications
  • Remediation programmes and independent-review support

How we engage

Three formats cover most needs, each built on one framework mapped across the relevant jurisdictions.

Framework review

A fixed-scope assessment of your existing AML and sanctions arrangements against the applicable regimes: what stands, what fails, and a prioritised remediation list with the regulatory deadlines mapped in.

Ongoing counsel

Continuing compliance support: list and regime tracking, policy maintenance, screening-calibration decisions documented, and a standing answer to the questions banks, auditors and funders raise.

Transaction and market-entry support

The compliance workstream in deals, expansions and the private transactions of wealthy individuals and family offices: counterparty diligence, sanctions analysis on structures and payment flows, and the one file built to carry the project through every gate.

Insights

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