Lithuania Issues Guidance on Detecting, Preventing Sanctions Evasion
Lithuania's Ministry of Foreign Affairs issued sanctions guidance July 17 on "detecting and preventing sanctions evasion and circumvention in trade." The document lists factors companies should take into account when conducting risk assessment, "red-flags in Russia or third country related…
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business operations, and guidance on due diligence when "estimating the risk on sanctions evasion and circumvention," and how to determine ownership and what is the "ultimate beneficial owner."