International Sanctions
Analysis of restrictive regimes and compliance obligations in cross-border transactions.
International transactions may be subject to restrictions imposed by different sanctions regimes, with distinct legal grounds and scope. In Brazil, Law 13,810 governs compliance with United Nations Security Council sanctions and cases involving the unavailability of assets. Foreign unilateral measures require an analysis of their connection to the transaction and their contractual or operational effects, without assuming that all lists have identical legal application in Brazilian territory.
The advisory work examines counterparties, control structures, financial flows and contract clauses. Screening procedures must address namesakes, incomplete information and alert escalation, avoiding decisions based solely on name matches. Reporting obligations and measures that depend on a specific legal basis are also assessed. The work connects sanctions with the prevention of money laundering, while preserving the distinction between these two regimes. Updates to the lists and changes in the transaction may require reassessing earlier conclusions.
Our work
- Analysis of the scope of restrictive regimes
- Clauses and procedures for counterparty screening
- Assessment of alerts, reporting and asset restrictions
Is a name match on a list enough to conclude that a sanction applies?
No. Identity, the regime's criteria, connections and the legal basis of the measure must be verified. The obligations arising from a confirmed match must be assessed according to the applicable rule.
Editorial review: