The increasing complexity of the sanctions agenda in 2026 requires a more in-depth analysis of the entire structure of the deal. To minimize risks, it is no longer enough to find a direct match: it is necessary to consider work through intermediaries and third countries, transparency of financial channels, supply chains, transport, and supply of goods falling into sensitive categories.

Today, sanctions risks can arise at various points in a transaction and be associated not only with international sanctions but also with domestic restrictive statuses.

Even if the counterparty itself appears safe, questions may arise regarding:

The problem with the classical approach is that it only answers one question: is there a direct match in a specific list. To eliminate hidden threats, the verification must be comprehensive.

The sooner you discover hidden limitations, the better your chances of protecting your transactions, maintaining supply chains, and avoiding reputational losses.

For Russian companies, verification should cover not only international sanctions lists, but also lists that are relevant to internal regulation, compliance, contractual work, and due diligence procedures.

These lists include:

For business, having such information can be of practical importance when:

In 2026, it will be especially important for businesses to see not only direct but also indirect signs of risk.

Affiliation. A formally neutral company may be part of a more complex corporate framework, where risk is generated at the level of ownership, management, or interconnected structures.

Financial infrastructure. International sanctions practice often affects the service environment surrounding a transaction. The 20th EU sanctions package specifically strengthens measures against financial services, crypto operators, and infrastructure used to circumvent restrictions.

Logistics. Screening should cover the entire transport chain: vessels, carriers, routes, port infrastructure and other elements of the chain. The EU also strengthened measures against elements of the "shadow fleet" and related assets in April 2026.

Internal restrictive statuses. It is important to check whether the counterparty or persons associated with it appear on lists of foreign agents, undesirable organizations, Rosfinmonitoring lists, or under special economic measures.

In 2026, business security will directly depend on how deeply compliance control is automated and integrated into your daily processes.

In these circumstances, it is especially important for businesses to use a reliable tool for checking, analyzing and monitoring restrictions. This solution is Sanctions Compliance module in Globas.

Sanctions Compliance module's capabilities include

In the context of increasingly stringent requirements for business transparency, companies increasingly need to not just formally check their counterparties, but also understand with whom exactly they are building business relationships. Identification of clients and counterparties is becoming an important part of risk management, internal control, and business protection systems.

In a real-case scenario, this raises a number of questions: what information needs to be verified, how to identify beneficial owners, where to look for information on PEPs, sanctions restrictions, and other risk factors. Inconsistency of the sources and the need to compare large volumes of data significantly complicate such work and increase the likelihood of missing important information.

Identification of companies within the framework of the Law No. 115-FZ is a mandatory procedure for organizations working with clients and funds. The main goal is to prevent money laundering and terrorist financing. Despite the formal nature of the requirements, actually we are talking about a basic check: with whom exactly the business is being conducted and what risks this may entail.

The requirements of the Law No. 115-FZ apply not only to banks. The obligation to identify clients has been established for a wide range of organizations, including:

In other words, if a company is involved in financial transactions or could potentially be used to conduct questionable transactions, it is subject to compliance control requirements.

Identification is not only a collection of basic company details such as name, TIN and address. As a rule, it involves a deeper check, including several key areas.

1. Beneficial Owners Check
It is important to establish who ultimately controls the company and benefits from its activities. These may be individuals who directly or indirectly own shares in the business or exercise a decisive influence on decision-making.

2. Identification of Politically Exposed Persons (PEPs)
It is necessary to determine whether the owners, executives or other related persons are classified as politically exposed persons or are among their close relatives. Such individuals are considered to be in a high-risk category and are therefore subject to increased scrutiny.

3. Screening Against Sanctions Lists
The company, its owners and executives must be checked for inclusion on sanctions lists. Working with such counterparties can lead to serious legal, financial and operational consequences.

4. Assessment of Business Reputation and Risk Factors
In addition, companies analyze the presence of negative information, litigation, signs of bankruptcy, as well as other factors that may indicate the unreliability of a counterparty.

Together, this type of verification allows for a more complete understanding of a client or counterparty and reduces the likelihood of making risky decisions.

Compliance with the requirements of the Law No. 115-FZ is under constant government control, primarily by Rosfinmonitoring (Federal Financial Monitoring Service). This body performs financial intelligence functions and coordinates the system of combating money laundering and terrorist financing.

Entities subject to the law are required to:

In particular, if entities refuse to provide services to a client due to identified risks, the relevant information may also be transferred to Rosfinmonitoring. This creates a unified data exchange system that allows for the identification and tracking of potentially risky transactions and market participants.

At first glance, the requirements may be perceived as a formality, but in practice they are aimed at protecting the company itself. Verification of clients and counterparties allows you to:

Having a well-established compliance control system is becoming an essential element of sustainable and responsible business operations.

Failure to comply with the Law No. 115-FZ may result in serious consequences. Among them:

In some cases, violations may have more serious legal consequences if they involve participation in illegal activities.

In practice, compliance with the requirements of the Law No. 115-FZ is associated with a number of difficulties. There are no unified and comprehensive registers of politically exposed persons available to the public, sanctions lists are fragmented, and assessing business reputation and risk factors requires analyzing information from a large number of sources. As a result, companies are forced to collect, collate, and verify information themselves, which increases labor costs and creates the risk of missing important data.

Therefore, many subjects of the Law No. 115-FZ use specialized solutions. One of such solution is Globas.

Globas provides a set of tools for verifying and identifying clients and counterparties as part of compliance control:

1. Beneficial Owners Check
Globas helps to build an ownership structure and identify the ultimate owners of a company, including in the presence of complex corporate relationships.

2. Identification of Politically Exposed Persons
Globas implements verification of affiliation with Russian and foreign politically exposed persons. The system uses an extensive database, which allows you to identify such signs without manually searching through multiple sources.

3. Screening Against Sanctions Lists
The system enables automated verification against key sanctions lists, reducing the risk of interacting with contractors subject to restrictions.

4. Assessment of Risks and Business Reputation
Globas helps identify unreliability factors, analyze risks, and form a more holistic picture of the company, its owners, and associated parties.

Thus, using Globas brings an automation of a significant portion of compliance procedures, reduces the workload on employees, and improves the quality of client and counterparty verification.