Sanctions, Export Control and Foreign Exchange Operations

Other areas of expertise:

Global supply chains, geopolitical tensions, and stricter financial oversight mean that sanctions, export control, and foreign exchange rules directly affect almost every sector.

Companies face prohibited transactions, jurisdiction-based restrictions, obligations relating to dual-use goods and technologies (including software and encryption), as well as strict payment traffic and reporting rules.

Our team supports manufacturers, exporters, importers, SaaS/cloud and fintech companies, logistics providers, banks, and traders in anticipating risks, maintaining access to banking channels, and operating safely across multiple markets.

Why Zunic Law

End-to-end approach: from risk assessment and policy design, through contractual clauses and licensing, to communication with banks and competent authorities.
Industry understanding: technology and software (encryption, remote access), machinery and components, energy and raw materials, trade and logistics, fintech and banking.
Operational delivery: clear steps, decision matrices, document templates, and files ready for regulators, banks, or partners.
Cross-border experience: bilingual documentation (SR/EN) and coordination of regimes (EU/UK/US and local rules).

Key Areas of Work

Sanctions regimes and restrictive measures
Prohibited and restricted transactions
Export control and dual-use (including software and technology)
Licenses and authorizations
Third-party screening and due diligence
Logistics, customs and supply chain
Financial sector and payments
Foreign exchange operations (residents and non-residents)
Contracts, collections, and risk insurance
Investigations, incidents, and remediation
Training and compliance programs

Below, we provide a more detailed overview of the key areas of work:

1) Sanctions regimes and restrictive measures

Mapping applicable regimes (EU, UK, US, UN, and local regulations) and determining the strictest application – we provide an overview of all relevant legal frameworks, identify conflicts, and advise on which regime to apply to minimize risk.
Ownership and control (e.g., the “50%/control” rule), indirect exposure, and “shadow” risks – we analyze formal and informal ownership links, hidden structures, and affiliates to avoid accidental cooperation with sanctioned entities.
Sectoral prohibitions (e.g., energy, transport, finance), asset freezes, and prohibitions on providing certain services – we help clients understand the boundaries of doing business in sensitive industries and develop mechanisms to verify the permissibility of each transaction.

2) Prohibited and restricted transactions

Assessment of permissibility of payments and deliveries, geographical and sectoral restrictions – we create decision matrices that allow operational teams to quickly determine whether a transaction is permissible.
Sanctions/restrictions clauses in contracts: termination, suspension, refund, “force majeure” and “change in law” – we integrate protective mechanisms into contracts, enabling companies to exit risky arrangements without financial or legal consequences.

3) Export control and dual-use (including software and technology)

Classification of goods/software/technology (tariff codes, dual-use logic, encryption) – we conduct detailed technical-legal analyses to determine whether goods or software fall under control lists.
Re-export, “deemed export,” brokering, transfer of technical data, and remote access – we explain how even digital actions (e.g., sharing code, remote server access) may constitute export in legal terms.
End-use and end-user checks, end-user statements, and usage restrictions – we develop due diligence protocols to ensure that products and technologies are not misused.

4) Licenses and authorizations

Licensing strategy and preparation of applications to competent authorities – we support the selection of the most efficient path (individual licenses, general licenses, exemptions).
License conditions, monitoring compliance, and reporting; managing deviations and amendments – we provide ongoing support after a license is issued, ensuring compliance throughout the transaction lifecycle.

5) Third-party screening and due diligence

Establishing restricted party screening processes and periodic re-screenings – we implement procedures that allow continuous monitoring of partners, customers, and suppliers.
Beneficial ownership and “look-through” analysis; red flags and escalations – we uncover hidden ownership structures and set up clear escalation protocols when risky connections are identified.

6) Logistics, customs and supply chain

Transit, diversions, and “circumvention” risks; route and intermediary control – we advise on preventing sanctions evasion through indirect channels.
Documentation for customs and carriers; compliance with record-keeping obligations – we prepare documentation packages that reduce the risk of goods being detained and fines imposed.

7) Financial sector and payments

Correspondent banking rules, “de-risking,” blocked/declined transactions – we help prepare documentation in advance to give banks confidence in the legitimacy of transactions.
Compliance with payment processors’ and card schemes’ requirements; records and explanations of payment purpose – we provide ready-made explanation models and internal procedures that speed up transaction approvals.

8) Foreign exchange operations (residents and non-residents)

Permitted/restricted transactions, residency status, contracting of currency and payment terms – we interpret specific rules for residents and non-residents and propose optimal contractual models.
Documentation for banks, proof of payment grounds, records, and regulatory reporting – we provide document templates easily adaptable to each transaction.
Capital transactions (loans, guarantees, investments), dividend transfers, and other common situations – we create practical guides for carrying out capital transactions without regulatory breaches.

9) Contracts, collections, and risk insurance

Currency clauses, collection terms, and sanctions compliance guarantees – we develop contractual mechanisms that protect companies from changes in the legal environment.
Export credit insurance, credit insurance, letters of credit, and collection arrangements – we advise on payment protection instruments and their alignment with sanctions and foreign exchange rules.

10) Investigations, incidents, and remediation

Internal investigation of suspicious transactions, “stop-the-bleed” measures, corrective plans – we provide methodology for rapid response, minimizing damage, and documenting the case.
Voluntary self-disclosures where appropriate, negotiations with partners and banks, recovery of funds where possible – we explain the advantages and risks of self-reporting and conduct negotiations to mitigate reputational and financial consequences.

11) Training and compliance programs

Tailor-made training for sales, procurement, logistics, legal, and finance (in-house or online) – training is adapted to the client’s business model and industry, with practical examples.
Playbooks for front-line teams: what to do when screening “flags,” how to document a decision, and whom to notify – we provide ready-made guides that facilitate fast and proper reactions in operations.

Services We Provide

Risk assessments and compliance programs: risk maps for markets, products, and payment flows; policies and SOPs (sanctions, export controls, FX).
Classification and licensing: classification reports, end-use/end-user packages, preparation and management of license procedures.
Contracts and transactions: drafting/reviewing contracts and tender documentation, sanctions and export-control clauses, termination/suspension models.
Banks and payments: preparation of KYC/“source of funds” packages, explanations of payment purpose, communication with banks and processors.
Investigations and remediation: internal investigations, corrective action plans, reports for management and stakeholders.
Training: role-specific programs (sales, procurement, logistics, legal/finance), with case studies from your industry.

Who Engages Us

Manufacturers and exporters of technology, machinery, components, and software.
Distributors and logistics companies (transport, forwarding, 3PL/4PL).
Banks, fintech and payment providers, traders, and marketplaces.
Energy, raw materials, and industries with a high share of international trade.
IT/SaaS and cloud providers (encryption, remote access, global teams).

Typical Projects

Policies and procedures: sanctions, export controls, FX operations; escalation matrices and checklists.
Reports: product/software classification, end-use/end-user risk assessment, risk maps by market.
Contractual documents: sanctions and export-control clauses, reps & warranties, termination/suspension, “change in law.”
Dossiers for licenses and banks: applications, supporting documentation, statements, and communication packages.
Investigations and remediation: minutes, corrective plan, communication with partners/banks.

How Cooperation Works (4 Steps)

Discovery and risk scan — understanding products/services, markets, payment flows, and suppliers; identifying quick wins and critical gaps.
Plan and priorities — defining policies, processes, contract amendments, and possible licenses; setting responsibilities and deadlines.
Implementation — templates and SOPs, contractual clauses, screening and due diligence, license preparation, and communication with banks.
Maintenance — periodic re-screening and policy updates, training of new teams, support in incidents, and regulatory changes.

Tijana Žunić Marić

Jelena Đukanović

Frequently Asked Questions (FAQ)

If we only export software and “cloud,” do we need licenses?

Possibly. Even without physical export, software and cloud services may contain encryption or technical data subject to export control regimes. Remote server access and transfer of technical knowledge are also reviewed. Classification of software, as well as end-use and end-user assessments, is necessary.

Can we work with an entity that is not listed, but is majority-owned by a sanctioned party?

It is necessary to examine ownership/control rules (e.g., the “50% rule”) and analyze indirect connections. In many cases, deep due diligence of the ownership structure and business activities is required.

Even if the entity is not formally listed, exposure may be significant, and operations risky.

Why does a bank block or delay a payment and request additional documentation?

Banks are required to apply strict KYC and AML procedures and comply with international sanctions.

Additional documentation is often requested to prove the grounds and purpose of payment.

We prepare complete packages, including contracts, invoices, statements, and explanations, to clear blocked transactions.

How to reconcile multiple regimes (EU/UK/US and local rules)?

Our practice is based on applying the “strictest rule” – i.e., the regime that is most restrictive in a given situation.

We create decision matrices that allow practical and sustainable application of rules in daily operations without paralyzing processes.

What if an unintentional violation occurs?

The most important step is to immediately halt relevant activities and prevent further exposure.

We conduct an internal investigation (“root cause analysis”), define a remediation plan, and prepare reports for management and relevant partners.

Depending on the situation, voluntary self-disclosure to regulators may be recommended, which can mitigate consequences and demonstrate good faith.

Is an internal compliance officer sufficient, or is external support necessary?

An internal team is crucial, but in practice, it often lacks the time or specialized knowledge for complex cases (especially in cross-border regimes).

Our role is to provide expertise, templates, and methodology so that the internal team can apply the rules and independently manage operational processes.

How to ensure the supply chain does not present risks?

Periodic supplier screening, intermediary and documentation checks, and route controls must be implemented.

We help companies establish procedures that identify risk points and prevent circumvention attempts, which is particularly important in transit and re-export situations.