PracticesSanctions, Export Control and Foreign Exchange Operations
Practice area

Sanctions, Export Control and Foreign Exchange Operations

Risk assessment, classification, licensing and compliance for companies trading, paying and shipping across multiple jurisdictions.

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

Companies face prohibited transactions, jurisdiction-based restrictions, obligations on dual-use goods and technologies including software and encryption, and strict payment and reporting rules.

We support manufacturers, exporters and importers, SaaS, cloud and fintech companies, logistics providers, banks and traders in anticipating risk, keeping access to banking channels and operating safely across markets.

The work is operational: clear steps, decision matrices, document templates and files ready for regulators, banks or partners, in Serbian and English.

Key practice areas

What we handle

Eleven areas of work across sanctions, export control and FX.

01

Sanctions regimes and restrictive measures

  • Mapping of the applicable regimes (EU, UK, US, UN and local rules) and determination of the strictest that applies.
  • Ownership and control analysis, including the 50% rule, indirect exposure and shadow risk.
  • Sectoral prohibitions in energy, transport and finance, asset freezes and service bans, with mechanisms to verify each transaction.
02

Prohibited and restricted transactions

  • Assessment of whether payments and deliveries are permitted under geographic and sectoral restrictions.
  • Decision matrices that let operational teams determine permissibility quickly.
  • Sanctions clauses in contracts: termination, suspension, refund, force majeure and change in law.
03

Export control and dual-use goods

  • Classification of goods, software and technology (tariff codes, dual-use logic, encryption).
  • Re-export, deemed export, brokering, transfer of technical data and remote access.
  • End-use and end-user checks, statements and usage restrictions.
04

Licences and authorisations

  • Licensing strategy and preparation of applications to the competent authorities.
  • Selection of the most efficient route: individual licences, general licences or exemptions.
  • Licence conditions, compliance monitoring and reporting, and management of deviations and amendments.
05

Third-party screening and due diligence

  • Restricted party screening processes and periodic re-screening.
  • Beneficial ownership and look-through analysis.
  • Red flags and escalation protocols where risky connections appear.
06

Logistics, customs and supply chain

  • Transit, diversion and circumvention risk, with route and intermediary controls.
  • Documentation for customs and carriers.
  • Compliance with record-keeping obligations that reduce the risk of detained goods and fines.
07

Financial sector and payments

  • Correspondent banking rules, de-risking and blocked or declined transactions.
  • Documentation prepared in advance so banks can see the transaction is legitimate.
  • Compliance with payment processor and card scheme requirements, with records and explanations of payment purpose.
08

Foreign exchange operations

  • Permitted and restricted transactions, residency status, contracting of currency and payment terms.
  • Documentation for banks, proof of the grounds for payment, records and regulatory reporting.
  • Capital transactions — loans, guarantees, investments — and dividend transfers.
09

Contracts, collections and risk insurance

  • Currency clauses, collection terms and sanctions compliance guarantees.
  • Export credit insurance, credit insurance, letters of credit and collection arrangements.
  • Contractual mechanisms that protect against changes in the legal environment.
10

Investigations, incidents and remediation

  • Internal investigation of suspicious transactions and immediate containment measures.
  • Corrective action plans and documentation of the case.
  • Voluntary self-disclosure where appropriate, negotiations with partners and banks, and recovery of funds where possible.
11

Training and compliance programmes

  • Tailored training for sales, procurement, logistics, legal and finance, in-house or online.
  • Playbooks for front-line teams: what to do when screening flags a name, how to document the decision and whom to notify.
  • Policies, SOPs and risk maps for markets, products and payment flows.
How we work

What working with us looks like

Four steps, from the first risk scan to ongoing maintenance.

01

Discovery and risk scan

We map products, services, markets, payment flows and suppliers, and identify quick wins and critical gaps.

02

Plan and priorities

We define policies, processes, contract amendments and any licences needed, with responsibilities and deadlines.

03

Implementation

Templates and SOPs, contractual clauses, screening and due diligence, licence preparation and communication with banks.

04

Maintenance

Periodic re-screening, policy updates, training for new teams and support in incidents and regulatory change.

Track record

Selected matters

A sample of recent work in the sector.

Policies

Sanctions and FX programme

Policies, procedures, escalation matrices and checklists across sanctions, export control and foreign exchange.

Classification

Product and software classification

Classification reports with end-use and end-user risk assessment and risk maps by market.

Contracts

Sanctions clauses

Sanctions and export-control clauses, representations and warranties, termination, suspension and change-in-law provisions.

Banking

Licence and bank dossiers

Applications, supporting documentation, statements and communication packages for authorities and banks.

What Clients Ask Us Most

If we only export software and cloud services, do we need licences?

Possibly. Even without physical export, software and cloud services may contain encryption or technical data subject to export control. Remote server access and transfer of technical knowledge are also assessed.

Classification of the software, together with end-use and end-user assessment, is necessary.

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

Ownership and control rules — such as the 50% rule — have to be examined, along with indirect connections. In many cases deep due diligence of the ownership structure is required.

Even where the entity is not formally listed, exposure can be significant and the business risky.

Why does a bank block or delay a payment?

Banks apply strict KYC and AML procedures and must comply with international sanctions. Additional documentation is often requested to prove the grounds and purpose of the payment.

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

How do you reconcile several regimes at once?

Our practice applies the strictest rule: the regime that is most restrictive in the situation at hand.

We build decision matrices so the rules can be applied in daily operations without paralysing the process.

What if an unintentional violation occurs?

The first step is to halt the relevant activity and prevent further exposure. We then run an internal root cause analysis, define a remediation plan and prepare reports for management and partners.

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

Is an internal compliance officer enough?

An internal team is essential, but in practice often lacks the time or specialist knowledge for complex cross-border cases.

Our role is to supply the expertise, templates and methodology so the internal team can apply the rules and run the process independently.

How do we make sure the supply chain is not a risk?

Through periodic supplier screening, checks on intermediaries and documentation, and route controls.

We help establish procedures that identify risk points and prevent circumvention, which matters most in transit and re-export situations.

Next step

Let’s talk about your exposure

Tell us what you ship, license or pay for and we will map the regimes that apply.

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