International Business and Sanctions Compliance: Questions to Ask Before a Deal
By Dion Macbeth, California attorney
Cross-border transactions can create regulatory exposure even when a counterparty appears private. Screening, ownership analysis, payment routes, goods, and end use should be addressed before the deal is operational.
Screen the whole transaction
Review counterparties, beneficial owners, banks, countries, products, services, end users, shipping routes, and intermediaries. Contractual representations help but do not replace a risk-based compliance process.
Build escalation into the contract
Agreements should address compliance obligations, information rights, suspension, termination, audit cooperation, and what happens when law or sanctions change. A clear escalation path protects the business when facts are uncertain.
Common Questions
Further Detail
Yes. Private ownership does not eliminate risk arising from counterparties, beneficial owners, transactions, goods, services, or payment channels.
Before signing or moving funds when a transaction touches a higher-risk country, industry, counterparty, product, or intermediary.
Legal Guidance
Discuss This Matter With Harrington Wells
Contact Harrington Wells to request an initial review. The firm will determine whether the matter falls within its current scope and capacity.
Related practiceInternational LawRequest ConsultationThe information provided does not constitute legal advice and does not create an attorney-client relationship.