Tracking OFAC/EU sanctions overlap in EM
With the increasingly complex global sanctions landscape, especially regarding dual-listed EM entities or those with significant cross-border operations, how are others managing the real-time reconciliation of OFAC vs. EU sanctions lists? The nuances in designation criteria and delisting processes create genuine operational friction for due diligence, particularly when navigating local counsel advice in jurisdictions with varying enforcement appetites. Are firms seeing more false positives or outright missed flags due to the divergence, or have standardisation efforts mitigated this somewhat?
It's a persistent headache, especially when you're dealing with entities that are perpetually on the cusp or have a web of subsidiaries. Are you primarily concerned with the designation process differences or the practicalities of data reconciliation once a listing hits?