Beyond routine screening, navigating the global sanctions landscape requires high-level strategic legal counsel. The fluid geopolitical environment, coupled with Georgia's position as a key regional trade and financial hub, creates a complex web of legal and commercial risks. Companies and investors face conflicting legal regimes, aggressive extraterritorial enforcement, and significant "de-risking" pressure from international financial partners. Legal Sandbox Georgia provides an expert advisory service to help senior management, investors, and boards of directors understand this landscape, make informed strategic decisions, and structure their operations and investments for maximum compliance and resilience.
Advisory on Extraterritorial Sanctions (US Secondary Sanctions, UK, EU)
This advisory service provides critical clarity on one of the greatest risks to Georgian businesses: extraterritorial jurisdiction. We analyze how foreign laws apply to your purely local or third-country transactions. Our counsel focuses on US Secondary Sanctions, which force a choice between transacting with a sanctioned party (e.g., in Iran or Russia) and accessing the US financial system. We also advise on the reach of the UK's Russia (Sanctions) Regulations, which can designate non-UK persons in Georgia for undermining the sanctions regime. We analyze your exposure to being cut off from USD clearing, correspondent banking, and the London insurance market, providing a clear map of your legal and financial vulnerabilities to foreign enforcement actions.
Guidance for Georgian Entities Trading with Sanctioned Regions
We provide specialized legal guidance for companies whose business models involve high-risk jurisdictions. While Georgia may not have identical sanctions lists, the National Bank of Georgia explicitly mandates all Georgian financial institutions to comply with US, EU, and UK financial sanctions. This creates a de facto domestic enforcement mechanism. Our advisory service analyzes this specific risk. We review your proposed trade, logistics, and payment channels for any involvement of designated parties, banks, or transport providers. We advise on the extreme risks of re-export, product diversion, or "Made in M" rebranding schemes, which are aggressively targeted by Western authorities as sanctions evasion and can lead to your company and its directors being designated.
Sanctions Risk Mapping for Investors and Financial Institutions
For investors, private equity firms, and financial institutions, we conduct a top-down sanctions risk assessment of a target investment, portfolio, or the institution itself. This is a macro-level due diligence process mandated by Georgian AML/CFT regulations. We analyze your inherent risks based on your specific customer profiles, product types, service delivery channels, and geographic footprint. We build a formal risk map that identifies high-risk areas (e.g., a real estate portfolio with opaque UBOs, a trade finance division banking the logistics sector) and provides a clear remediation plan to implement proportional controls, satisfying the risk-based approach demanded by the National Bank of Georgia and international partners.
Support for Fintech, Crypto, and Digital Asset Service Providers
The fintech and crypto sector is not a regulatory grey zone; it is a primary focus for Georgian regulators. As of 2023, all Virtual Asset Service Providers (VASPs) must register with the National Bank of Georgia and are subject to the same comprehensive AML/CFT and financial sanctions laws as traditional banks. We guide VASPs through this mandatory compliance framework. Our service includes developing the required risk-based compliance programs, policies for KYC (including UBO verification), and adherence to all UN, US, EU, and UK sanctions lists. We ensure your platform, wallet service, or exchange is fully compliant with NBG regulations before you face an audit, fine, or license revocation.
Sanctions Impact Assessments on Contractual Performance and Force Majeure
When sanctions prevent you or a counterparty from fulfilling a contract, it triggers a complex legal dispute. We provide a formal legal assessment of whether international sanctions constitute a force majeure event under a contract governed by Georgian law. Georgian contract law and court precedent (e.g., regarding government-imposed trade interruptions) recognize "government acts" and "embargoes" as potential force majeure events. We analyze your specific contract's force majeure clause, the exact sanction imposed, and the factual link preventing performance (e.g., an asset freeze blocking payment). We then provide a formal legal opinion on your rights to suspend or terminate the contract, or your defenses if a counterparty claims force majeure against you.
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