Client : Confidential
Completed : Q1 2025
Our clients trust Themis with some of their most sensitive and high-stakes decisions. In turn, we take every precaution to protect their identities, the subjects of our investigations, and the integrity of our investigative team. While the details in this case are anonymised, the risk uncovered—and the value we delivered—is very real.
In early 2025, an international law firm engaged Themis to conduct Enhanced Due Diligence into a global commodities trading house. The client was considering representing the company in a legal capacity and required a comprehensive understanding of the subject’s financial crime risk profile—specifically in relation to sanctions exposure following the outbreak of the war in Ukraine and evolving trade restrictions with Russia.
The subject company had a large and complex global footprint, making traditional screening and surface-level analysis inadequate. Its high profile meant significant volumes of historic litigation, regulatory scrutiny, and public attention to sort through. The client needed a partner that could distinguish between material risk and noise—particularly in a sanctions environment that was fast-changing and politically charged.
To meet the client’s objectives, Themis conducted a multi-faceted investigation across several areas:
Adverse Media & Litigation Review
Analysts sourced and reviewed media coverage, legal records, and court filings to provide a clear chronology of key events and assess reputational and legal risk.
Sanctions & Trade Flow Analysis
Leveraging trade intelligence tools, our team analysed hundreds of bills of lading to identify shipments associated with the subject company that had entered Russia post-February 2022. Goods were matched against Harmonised System (HS) codes flagged in sanctions lists from the US (OFAC), the EU, and the UK.
Ownership & Directorship Mapping
Our analysts screened directors and Ultimate Beneficial Owners (UBOs) for sanctions exposure and identified continuing links to Russian-based entities and PEPs, despite claims of disengagement from the region.
Multiple shipments from the subject company to Russia included goods potentially subject to international sanctions.
Ongoing operations in Russia contradicted the firm’s public statements, including active branch listings and trade records.
Links to sanctioned entities were identified through layered ownership structures, including shareholdings and directorships.
Politically exposed individuals were found to retain control over key decision-making within the trading house.
Our investigation enabled the client to gain clarity and confidence before proceeding with legal representation. The findings highlighted specific risk areas related to sanctions, reputational exposure, and regulatory scrutiny—allowing the law firm to assess alignment with its own risk appetite and prepare appropriately for potential future developments.
The case reinforced the importance of targeted, in-depth intelligence gathering when dealing with high-profile subjects in complex and sensitive environments.
The Themis Intelligence team was engaged by an international law firm to conduct an Enhanced Due Diligence into a major global commodities trading house. Our client, ahead of representing the subject company, wanted to gain a complete picture of the trading house’s financial crime risk profile with a particular focus on sanctions exposure pertaining to trade and other engagement with Russia.
In order to meet our client’s needs, our team first conducted a comprehensive review of adverse media and litigation cases pertaining to the subject. As the firm in question had a significant public profile, this involved identifying a range of reputable sources and isolating key details to provide clear and detailed information on historic and recent cases. An awareness and understanding of outstanding legal proceedings concerning a subject is often a key concern for our clients, and in-depth searches and analyses of court documents, docket records and media reporting help our team support our client’s requirements in this area.
Additionally, our analysts carried out a trade review of shipments associated with the subject company and arriving in Russia following the imposition of international sanctions against many goods entering the country since February 2022. An analysis of hundreds of bills of lading allowed us to isolate a number of shipments associated with Harmonised System (HS) codes linked to goods sanctioned variously by the US Office of Foreign Assets Control (OFAC), the European Union, the United Kingdom, and others.
Moreover, to further enhance our client’s understanding of the sanctions risk pertaining to the trading house, or team carried out risk screening on the directors and Ultimate Beneficial Owner (UBO) of the subject company and evaluated the status of the firm’s Russian branches. In doing so, our analysts identified additional links to sanctioned entities, including through shareholdings and directorships, as well as providing an up-to-date understanding of the Politically Exposed Persons (PEPs) with significant control over the trading house.
As a result of our investigation, our client was able to gain current and actionable information regarding financial crime and reputational risk pertaining to the target company in a complex and rapidly changing political environment and understand potential sanctions exposure posed by the target company’s Source of Funds.
