Sanctions Compliance for Mid-Market Companies

Sanctions regimes change quickly and apply to companies of every size. Mid-market businesses often face the same risks as larger groups, through their customers, suppliers and payment routes, without the resources of a dedicated compliance department.

This paper sets out a proportionate approach: a written risk assessment, screening that matches the business's real exposure, contractual protections with counterparties, and clear escalation routes when a potential match appears. It also explains how ownership and control rules can bring apparently unconnected parties within scope.

A final chapter addresses what to do when something goes wrong, including internal review, voluntary disclosure and the management of relationships with banks and insurers while the matter is resolved.