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Compliance · International sanctions · Export controls

Trade.Structure.Prove.

We secure your flows, subsidiaries and contracts before customs, your bank or the prosecutor ask the question.

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  • 21st package · 23.07.2026 —
  • 22nd package · 12.10.2026 —
  • approx. 1,600 new listings —
  • Belgium: criminal regime reformed since 01.09.2026 —
  • Regulation (EU) No 833/2014 —
  • Regulation (EU) No 269/2014 —

In figures

02In figures

sanctions packages against Russia since 2022, two of them adopted in 2026
22
new listings, approximately, added by the 22nd package of 12 October 2026
1,600
banks and financial institutions hit by asset freezes in the 21st package
94
maximum prison term for individuals in Belgium since 1 September 2026
5yrs

An exporting SME, a trader or a group with a subsidiary outside the EU is concerned, even if it never sells directly to Russia.

03Before you ship

Six checks before every order

Each check leaves a trace: date, code, table version used, decision. Kept for five years.

  • The question

    Where are the goods really going?

    The proof to keep

    Signed end-use and no-re-export statement for any customer in a diversion-risk country.

  • Vague end-use
  • Business mismatch
  • Odd routing
  • Unusual payment

One signal is enough to pause and verify.

04The holding test

A holding in a third country does not set the group free

01EU parent companyCONTROL CHAIN02Third-country holding03Subsidiary in Russia
  1. 01The control chain survives.
  2. 02The duty extends to the holding: no means, staff or logistics may serve a breach.
  3. 03Only an externally caused loss of control can limit the obligation.
  4. 04A sudden third-country entity in the chain is a red flag for authorities (Art. 12).

Art. 13 — EU-national directors remain personally exposed, wherever they sit.

05Principle

Structure does not protect you.Discipline does.

06What your bank will ask

Request for additional information — Enhanced due diligence

0 / 8 ready

Prepare before you ship

A bank that freezes a payment almost always asks the same questions. We build the file upfront for sensitive flows, and defend it when the payment is already frozen.

07What we do

What we do

  1. 01

    Screening and classification

    Counterparties, beneficial owners, CN codes, dual-use items.

  2. 02

    Groups and non-EU subsidiaries

    Ownership and control, IT and IP ring-fencing, director exposure.

  3. 03

    Contracts and supply chain

    No-re-export clauses (Art. 12g), proof of origin, suspension, indemnity.

  4. 04

    Banks and frozen payments

    Document file and enhanced due-diligence answers.

  5. 05

    Procedures and training

    Sales, procurement and logistics procedures; controls register; team training.

  6. 06

    ESG and due diligence

    CSRD and CSDDD scope after Omnibus I, one shared supplier map.

  7. 07

    Investigations and market exit

    Customs and criminal defence, wind-down authorisations (Art. 12b), claims (Arts 11 and 11a).

08Who handles it

Who handles it

Sanctions analysis, banking compliance and AML, in one team.

09

Frequently asked questions

My subsidiary is outside the EU. Do sanctions apply?

Not directly, but the EU parent must use its best efforts to ensure it does not undermine sanctions (Art. 8a). An intermediate holding changes nothing.

My product is not on any list. Can I sell?

Not necessarily: transit, supplier restrictions and the catch-all can still require a licence.

My bank has frozen a payment. What now?

Answer quickly and completely, with documents. A file prepared upfront cuts the delay sharply.

What does the Belgian reform of 1 September 2026 change?

The Law of 13 May 2003, amended to transpose Directive (EU) 2024/1226, harmonises criminal enforcement. Individuals face up to five years' imprisonment.

10Contact

A shipment, a subsidiary, a frozen payment?

Response within 24 business hours.

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General information as at 11 November 2026; not legal advice.