Sanctions, integrity and responsible advisory work
Strategic Policy & Risk Advisory takes sanctions, integrity and responsible information handling seriously. This statement explains the principles SPRA applies when assessing sanctions and integrity risk in advisory, intelligence, due diligence, subscription, portal and client-document workflows.
SPRA does not seek to facilitate sanctions evasion, corruption, unlawful circumvention, misleading ownership structures or prohibited dealings. Where a proposed engagement, client instruction, counterparty, geography, sector or document set raises sanctions or integrity concerns, SPRA may request additional information, restrict scope, decline work, pause delivery or recommend specialist legal review.
This statement is not legal advice. Sanctions law is fact-specific and changes over time. Clients remain responsible for their own legal, sanctions, export control, procurement, contractual and regulatory compliance.
SPRA’s sanctions-aware workflow may refer to public and official sources including the UK Sanctions List, OFSI consolidated financial sanctions information, Companies House records, public corporate registries, procurement records, court or insolvency records, client-provided documentation and other reputable open sources relevant to the instruction.
SPRA does not claim access to classified government data and does not guarantee that public-source screening will identify every risk.
| Control area | SPRA practice | Client responsibility |
|---|---|---|
| Sanctions screening | Screen names, entities, projects or counterparties against relevant public sanctions sources where within scope. | Provide accurate names, aliases, ownership details, jurisdictions and supporting documents. |
| Ownership and control | Review available indicators of beneficial ownership, control, indirect links and red flags where relevant to the engagement. | Confirm ownership information and obtain legal advice where sanctions ownership/control rules may apply. |
| Enhanced due diligence | Escalate higher-risk sectors, jurisdictions, politically exposed links, opaque structures or adverse-source findings for deeper review. | Decide whether to proceed, pause, obtain legal advice or change project scope. |
| Document handling | Use controlled workflows for client documents and retain records according to data protection and retention policies. | Do not upload unlawful, misleading, unauthorised or unnecessary sensitive material. |
| Reporting and escalation | Where a matter suggests a legal reporting obligation or suspected breach, SPRA may pause work and recommend escalation to qualified advisers or appropriate authorities. | Make required reports and notifications where legally responsible to do so. |
Unclear beneficial ownership, recent restructuring, nominee arrangements, shell entities or unexplained changes in control.
Potential links to designated persons, controlled entities, restricted sectors, sanctioned jurisdictions or prohibited services.
Adverse media, corruption allegations, procurement irregularities, undisclosed conflicts, unusual payment routes or inconsistent documentation.
SPRA provides strategic intelligence and advisory support. It does not provide legal opinions, regulated financial advice, tax advice, government certification, sanctions clearance, export-control licensing or a guarantee that a client, counterparty, project or transaction is lawful or risk-free.
Sanctions and integrity assessments are limited by scope, source availability, data quality, date of review and the information provided by the client. Findings should be treated as decision support and may need legal, regulatory or specialist compliance review before action is taken.
This statement should be read together with SPRA’s Privacy Notice, Data Processing & Retention, Terms of Use, Ethics & Compliance and Sanctions & Integrity Due Diligence pages.
For sanctions or integrity-related enquiries, contact SPRA at info@strategicpolicyrisk.com or by telephone at +44 204 577 00 16.
Registered office: 4 St. Lukes Yard, London, England, W9 3AN
