Navigating sanction risks in an increasingly complex and rapid changing regulative environment is challenging. Norwegian entities that are directly or indirectly exposed to business partners in risk intense jurisdictions should conduct a sanctions risk assessment and implement targeted measures such as screening of counterparties and beneficial owners and negotiating robust compliance clauses in agreements. Having adequate and risk-based internal policies and procedures in place to ensure compliance with sanctions and other compliance risks such as money laundering and tax evasion is more important than ever.
Please note that these updates do not constitute legal advice, nor do they provide an exhaustive description of all sanctions in place and the exemptions. Any person or entity involved in business activities in any way related to Russia, Belarus or Ukraine should carefully assess how they are affected by the sanctions. Schjødt's sanctions team is ready to assist in this regard.