With constant changes in the geopolitical security landscape and a complex, rapidly evolving sanctions regime, it is vital for businesses to understand and comply with the regulations. We have extensive experience in assisting companies to adhere to sanctions regulations and offer tailor-made package solutions that help safeguard your business against sanctions risk.
Due Diligence Obligation – for Both Companies and Individuals
The sanctions rules impose a strict duty of due diligence on both companies and individuals, requiring that you know your business partners and their owners.
Both companies and individuals can face penalties for breaches of these rules. It is their responsibility to comply, and the strict due diligence requirement means that the threshold for involvement in violations is relatively low.
Regulatory and Operational Risk – and the Risk of Reputational Damage
When assessing sanctions exposure, one must consider regulatory and operational risks, as well as the risk of reputational damage.
Regulatory risk – including the risk of penalties and fines – increases as the sanctions regime develops rapidly. Additionally, banks, insurance companies, and others often impose stricter requirements than those mandated by the sanctions rules in order to provide their services, which creates an operational risk. For example, trading with certain countries can result in losing access to financial services or contracts, regardless of whether the parties involved are sanctioned.
Missteps and non-compliance with the sanctions regime can also lead to significant reputational damage for the business, as well as the risk of being disqualified as a supplier.
Sanctions from Both the EU and the USA
The sanctions implemented in Norwegian law essentially mirror those adopted by the EU. Furthermore, Norwegian businesses must be aware of the extensive reach of US sanctions.
Transactions linked to the US can be subject to US sanctions even if you do not operate within the US. US sanctions may come into effect, for example, if you use the US banking system, trade in dollars, or if US citizens are involved through ownership, board membership, or management.
Risk Assessments Related to Sanctions
To ensure compliance and reduce exposure to sanctions risk, it is crucial to perform thorough and risk-based due diligence assessments. This is particularly important when entering into contracts and transactions.
Sanctions-related risk assessments should be an integral part of a company’s compliance system and due diligence procedures.
Thommessen Sanctions Screen is Particularly Relevant for
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Businesses seeking to protect themselves against exposure to sanctioned parties.
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Companies without their own screening tools or sufficient expertise to conduct sanctions screening in-house.
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Companies that wish to have documented evidence of the investigations carried out, as a form of “insurance” should unforeseen circumstances arise in the future.
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Businesses looking to reduce the risk of liability under the sanctions rules, commercial risk, and reputational damage.
Our offer
Basic Sanctions Assessment
Price: NOK 6,000 to 9,000, depending on the nature of the assignment.
- Screening of companies and owners against sanctions lists in Norway, the EU, the UN, and the US.
- General OSINT (Open Source Intelligence) of companies and owners using open sources, with a focus on red flags.
- A concise summary of findings uncovered through screening and OSINT.
Extended Sanctions Assessment
Price: NOK 10,000 to 15,000, depending on the nature of the assignment.
- Screening of companies and owners against sanctions lists in Norway, the EU, the UN, and the US.
- Extended OSINT (Open Source Intelligence) of companies and owners using open sources, with a focus on red flags.
- A written report presenting the findings uncovered through screening and OSINT.
- An evaluation of the findings and the implications of any listing under Norwegian law, along with recommendations for the specific case.
In order to screen owners, the client must obtain ownership information from the company subject to assessments. At the start of the engagement, Thommessen will send a set of questions that can be used to gather this information.
How We Work
- We work proactively to identify potential challenges and solutions before contracts are finalised, and we assist with contract regulations.
- We act as strategic and legal discussion partners in all phases of a sanctions assessment.
- We provide practical advice tailored to the company’s risk appetite and strategy.
The Team
Thommessen has a multidisciplinary team with unique expertise in sanctions assessments:
Hedvig Moe
PARTNER // ADVOKAT
Hedvig has extensive experience with sanctions and export control from her previous role as head of counter-terrorism and deputy head at the Norwegian Police Security Service (PST). She also possesses in-depth knowledge of financial criminal cases from her tenure as acting director at the National Authority for Investigation and Prosecution of Economic and Environmental Crime (Økokrim).
Henrik Hagberg
PARTNER // ADVOKAT
Henrik has broad experience in sanctions assessments across the entire shipping and offshore sector.
Elin Ibsen Gustavsen
SPECIALIST ADVISOR //
Elin has specialised expertise in geopolitics and the threat landscape, with a particular focus on how these factors influence the sanctions environment. She assists with assessing country risk, reputational risk, and open-source investigations.
Sofie Mæland Tykvenko
SENIOR ASSOCIATE // ADVOKAT
Sofie supports Norwegian and international clients primarily within shipping. She has extensive experience conducting KYC checks and sanctions assessments.
Lovise Dahl
ASSOCIATE // ADVOKATFULLMEKTIG
Lovise has broad experience in sanctions assessments and screening of companies and individuals, performing KYC checks, and conducting ownership investigations. She also regularly carries out Integrity Due Diligence (IDD) on various companies.
Narve Nilssen
ASSOCIATE // ADVOKATFULLMEKTIG
Narve has extensive experience in sanctions assessments and has worked in the marine insurance industry, providing him with particular insight into the shipping sector. He has conducted numerous screenings of companies and individuals, KYC checks, and ownership investigations.
Oslo
Ruseløkkveien 38 0251 Oslo Postboks 1484 Vika NO–0116 Oslo
Bergen
Vestre Strømkaien 7 5008 Bergen Postboks 43 Nygårdstangen NO–5838 Bergen
Stavanger
Knud Holms gate 8 NO–4005 Stavanger
London
Level 19C – Tower 42 25 Old Broad Street GB–London EC2N 1HQ