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4 Okt 2023

Heartland Initiative

Managing risks created by Russia's invasion of Ukraine: Enhanced due diligence and advanced know-your-customer policies

4 October 2023

...Businesses have a responsibility to ensure they do not cause, contribute to, or are linked to human rights harms. There are serious legal, reputational, and regulatory risks for businesses whose components end up in Russian weapons used in violations of international law. To manage these risks, businesses must strengthen their human rights and know-your-customer (KYC) due diligence processes. At the same time, policymakers must update supply chain due diligence guidelines to ensure businesses operating in their jurisdictions do not unknowingly undermine sanctions placed on Russia and contribute to gross violations of human rights and humanitarian law.


  • Companies must allocate resources and put in place appropriate internal mechanisms and tools to empower their risk assessment departments to carry out enhanced due diligence of supply chains, intermediaries, customers, and end-users.
  • Companies must review their supply chain risk matrix to optimise their procedures for the regions that have been identified as emerging hubs for sanction diversion and circumvention and conduct enhanced due diligence during the onboarding of any new suppliers in these regions.
  • Companies must conduct a detailed review of the policies and procedures of their customers to ensure that they are able to prevent re-exports for military end-uses in Russia.
  • Companies must take into account potential red flags that consider the use of front companies by illicit networks to obfuscate the true end-user of products and evade sanctions and export controls.
  • Companies should collaborate with civil society experts to develop an industry standard-setting process and better monitoring, identification, and mitigation of risks.
  • Companies must create mechanisms for information exchange with governments and civil society groups to better investigate existing illicit networks and paths for components re-export to Russia and identify ways to disrupt them.
  • Companies must establish internal policies and procedures that enable them to rapidly investigate and respond in cases where their components are reported to have been integrated into military equipment used by Russia in Ukraine...

There are several tools available to assist companies in identifying potential red flags and enhancing human rights and KYC due diligence processes:

  • Refinitiv is a financial software that can provide the necessary capability to conduct risk and compliance analysis of supply chains. Its database can uncover hidden risks in business relationships and human networks, identifying high-risk or sanctioned entities and individuals.
  • Sayari Analytics is a financial intelligence platform allowing users to investigate ultimate beneficial ownership of companies and identify potential links to illicit activities and sanctioned entities. Sayari database can be used to build models of commercial and financial relationships to map out networks of companies linked by common identifiers across multiple jurisdictions.
  • Altana Trade Atlas is a dynamic AI platform that uses public and non-public data to enable greater visibility in supply chains across the globe. Altana conducts threat network analysis and AI targeting across global supply chains and business networks, to identify illicit network and trade activity.
  • OECD Due Diligence Guidance for Responsible Business Conduct - this guidance describes the due diligence process and supporting measures in a step-by-step fashion and can help set up due diligence processes or improve existing processes.
  • A Due Diligence Toolbox for SMEs, consisting of a self-assessment tool and an online practical manual, can be helpful for smaller companies looking to improve their due diligence processes...