Sanctions Compliance
We build sanctions control so that it holds up not only to the regulator's questions, but to the compliance teams at the banks your settlements depend on.
- Duration
- Two to six weeks
- Format
- Remote
- Result
- Policy, screening procedures and a risk matrix
Why a firm in Kazakhstan needs this
The objection comes up almost every time: Kazakhstan does not join unilateral sanctions, so why comply with them. In terms of legal duty, that is partly true. In terms of consequences, it is not.
Sanctions regimes are applied by your banks, payment providers, exchanges and counterparties. For them your sanctions control is a condition of doing business with you. The cost of a mistake is not measured in fines but in losing access to settlement, a closed account and terminated contracts, usually without discussion and within a day.
So we build sanctions compliance not as a formality for an inspector, but as something you can show a partner when they ask how your screening works.
How the work runs
- A diagnostic of the current state: which lists are used, how customers, counterparties and transactions are screened, whether a policy and procedures exist.
- An assessment of sanctions risk against your geography, products and customer base.
- Development or update of the sanctions policy and procedures: screening, escalation, blocking, documenting decisions.
- Configuration of screening tools or recommendations on them, including beneficial owners and connected parties.
- Staff training and testing of the process on real cases.
- Where needed, support during implementation and periodic effectiveness testing.
The lists firms usually work with:
- OFAC
- European Union
- United Nations
- United Kingdom
- Local lists
Which ones apply to you depends on where you operate and on what your partners require.
What happens on a hit
Any screening system can find a match. The procedure answers what the system does not: who reviews the hit, against which criteria, what happens next, and how all of it is recorded.
What we need from you
A description of products and customer segments, current procedures if any exist, information about where you operate and which payment channels you use, and access to the responsible staff.
Geography and payment channels matter more than anything else here: they decide which regimes touch you and where the risk appears.
What you get
Sanctions compliance policy
A document that describes your business and your risks, fit to be shown both to a regulator and to a partner bank.
Screening and response procedures
How checks, escalation and action on a hit are run, including how each decision is documented.
Risk matrix and checklists
Working tools for the people who decide on hits every day, not only for the folder.
Report and implementation plan
The gap between how it should work and how it does, with recommendations on tools and lists.
Timing
The timeline depends on the size of the business, the number of products and how much is being built from scratch. If sanctions control already exists and needs testing and tuning, the work goes faster than building from a blank page.
Frequently asked questions
Is screening the company name enough?
No. Beneficial owners and connected parties have to be screened too: restrictions extend to companies owned or controlled by listed persons. Name-only screening misses exactly the cases it exists for.
How often should lists be updated and customers rescreened?
Lists change constantly, so screening at onboarding is mandatory and the whole base is rescreened regularly and after significant list updates. The frequency is written into the procedure so that it does not depend on one person's memory.
We have screening in our system. Is that not enough?
The system covers finding matches. What it does not decide remains: what to do with a hit, who decides, within what deadline, how it is documented, and what happens when a customer is refused. The weak points sit there, not in the quality of the search.
What does it cost?
The fee depends on the size of the business, the number of products, the geography of operations, and whether the system is built from scratch or tested and tuned. We name an exact figure after a short conversation.
Shall we look at your case?
Tell us the task and we will say whether it needs the full piece of work or a narrower one.
Book a consultationNorthhold Advisory is an independent consultancy. We are not affiliated with, and do not represent, the AFM of Kazakhstan, the AIFC (AFSA) or the National Bank of Kazakhstan.