Artikel: Sanctions internal investigations

An internal investigation is a structured process by which an organisation establishes the facts relating to a specific allegation or concern and assesses potential breaches of applicable laws, regulations, or internal policies. Internal investigations related to breaches of international sanctions ("Sanctions Internal Investigations") conducted by organisations' own initiative are becoming a core element of compliance frameworks. As enforcement intensifies, regulators are likely to place greater reliance on companies to proactively detect, investigate, and remediate potential breaches in a structured manner, in line with internal investigation practices developed in other areas of regulatory compliance.

Whilst building on well-established principles in other practice areas, notably fraud and anti-corruption investigations, sanctions investigations present distinct challenges: violations may not be immediately apparent, often involving complex third-party relationships, opaque ownership structures, and fragmented multi-jurisdictional landscape that complicates voluntary self-disclosure strategy.

Lees verder:

• Sanctions internal investigations door C. (Coline) Cauvin en Y. (Yapa) Thepkanjana in Compliance, Ethics and Sustainability Journal