Written policies and procedures, screening workflow, allocation of responsibility within the organisation, record-keeping, internal control and periodic review.
A programme is not a document. What matters is whether it operates: whether screening actually runs before a payment leaves, whether an exception is recorded, whether someone owns the decision. Programmes are built to be evidenced, because evidence is what is examined later.
Identification of beneficial ownership; calculation of indirect ownership under the 50 percent rule, including aggregation across multiple blocked holders; vessel, owner and manager screening; port call and route analysis; identification of intermediaries and re-invoicing structures.
Assessment of a planned purchase, sale, charter or payment channel against the applicable regimes before the transaction is entered into — including which authorisation, if any, the transaction depends on, and what happens to the transaction if that authorisation is withdrawn.
Classification of dual-use goods and technology, end-user statements, re-export exposure, and the treatment of goods that pass through more than one jurisdiction.
Training for trade, logistics, procurement and finance teams, built on the organisation’s own transaction types rather than on generic case studies. Delivered in Turkish or English.
Legal services are provided by Sınırtaş & Partners, İstanbul