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BUSINESS PARTNER SANCTIONS DUE DILIGENCE FORM

INSTRUCTIONS FOR USER:

This is a questionnaire that you can use when conducting due diligence on a business partner.

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ACSS

Basic document outline

BUSINESS PARTNER SANCTIONS DUE DILIGENCE FORM

  1. Nature of the Relationship:

Customer __        Supplier __ Services Provider __        Counterparty __ Other __

For Individuals:

  1. Name:

  1. Residential Address:

  1. Business Address (if different):

  1. Country of Citizenship:

  1. Country of Residence:

  1. Birthdate:

  1. Identification Document No.:

  1. Form of Identification:

Passport __        National Identification Card __ Driver’s License __  Other __

For Entities:

  1. Legal Name:

  1. Doing Business As Name (if relevant):

  1. Legal Status:

Individual __ Corporation __ Limited Liability Company __ Partnership __ Other __

  1. Business Address:

  1. Mailing Address:

  1. Country of Organization:

  1. Ownership: List all legal owners of 10% or more of the entity, and provide the following information:

Legal Name:

Share of Ownership:

Country of Citizenship (if an individual):

Country of Organization (if an entity):

Address:

  1. Ultimate Beneficial Owners: List all individuals (natural persons) who own 10% or more of the entity, either directly or indirectly (i.e., because they own a sufficient share of an entity that in turn owns the entity in question), and provide the following information:

Name:

Share of Ownership in Upstream Entity (i.e., entity with an ownership share in the business relation):

Share of Ultimate Ownership (i.e., ultimate share of ownership in the business relation):

Country of Citizenship:

Address:

Business

Describe the nature of the business partner’s business:

  1. Is the business partner involved in any of the following businesses or industries?
  1. Aviation and jet fuel
  2. Finance
  3. Defense or military goods, services, or technology
  4. Petroleum or petroleum exploration, production, refining, or trading
  5. Natural gas
  6. Currency trading
  7. Charcoal
  8. Graphite, and raw or semi-finished metals
  9. Commodity trading
  10. Cryptocurrency
  11. Iron, steel, coal, zinc, or copper
  12. Gold, precious metals, diamonds
  13. Nuclear
  14. Luxury goods
  15. Goods, technology and services subject to dual-use and proliferation sensitive export controls
  16. Art
  17. Maritime shipping and bunkering services
  18. Marine insurance
  19. Telecommunications monitoring and interception equipment, technology or software 
  20. Logistics
  21. Energy
  22. Aerospace

  1. Does the business partner purchase from, sell to, or operate in any of the following countries? If so, identify which.

  1. Is the business partner a trading company or agent who purchases goods on behalf of other end-users? (If so, request a anti-diversion agreements that includes OFAC/sanctions compliance commitments).

© 2022 This template may be used by clients of the Association of Certified Sanctions Specialists (ACSS) in accordance with the License Agreement for the Sanctions Compliance Toolkit.