Detecting Sanctions Evasion Through Supply Chain Intelligence

We worked with an international client seeking to determine whether a European industrial company had continued operating in a high-risk market despite sanctions. The company had publicly indicated that it had withdrawn from the market, while direct trade flows had largely disappeared.

Our investigation combined customs data, corporate records, digital analysis and local-source verification. We identified continued commercial activity in the region, a rerouted multi-jurisdictional supply chain for dual-use goods, and commercial relationships with sanctioned entities. By reconstructing the network of suppliers, intermediaries, logistics providers and recipients, we provided the client with an evidence-based assessment of the company’s ongoing exposure and the mechanisms used to maintain it.

Client

An international client requiring an independent assessment of sanctions, supply-chain and reputational risks associated with a European industrial company.

Task

• Determine whether the target company had retained exposure to a high-risk market despite sanctions.

• Identify any indirect supply routes, intermediary entities and commercial relationships that could indicate continued operations or sanctions circumvention.

Solution

Building a multi-source intelligence dataset

• We conducted a comprehensive review of public and commercially available information across multiple jurisdictions and languages.

• Using custom-built data scrapers, we gathered and structured large volumes of fragmented information, including corporate records, regulatory filings, digital content and commercial data.

• This enabled us to build a consolidated intelligence picture of the target’s ownership, operations, counterparties and international exposure.

Reconstructing the supply chain

• We analysed more than 20,000 shipment records to assess how the company’s trade patterns had changed following the introduction of sanctions.

• The analysis identified indirect supply routes involving intermediaries across several jurisdictions and revealed links between European suppliers, logistics providers, regional entities and customers in the high-risk market.

  
  

Digital and regulatory analysis

• We assessed the target’s wider digital and regulatory footprint to establish the extent of its continued activity beyond the shipment data.

• The analysis covered current and archived product materials, social media and press releases, recruitment and exhibition activity, regulatory certifications, litigation and procurement records, and evidence of ongoing commercial relationships in the high-risk market.

• This helped confirm that products identified in the reconstructed supply chain remained actively marketed and commercially supported after the introduction of sanctions.

  
  

Local-source verification

• To strengthen confidence in the digital findings, we supplemented the investigation with targeted local enquiries and input from our network of regional experts.

• This provided independent context on the target’s continued presence and helped verify selected indicators of commercial activity in the high-risk region.

Impact

• Our investigation established that the company retained exposure to the high-risk market through continued commercial activity and a rerouted supply chain involving intermediaries across multiple jurisdictions.

• We also identified deliveries connected to sanctioned entities and product categories subject to export restrictions.

• The client received a documented reconstruction of the commercial network, including the entities, trade routes and operational links supporting the company’s continued exposure.

• The findings provided a defensible basis for sanctions-risk assessment, enhanced due diligence and further legal or compliance review.