Purpose
Map a company's international operations against the major sanctions regimes and produce a prioritized, review-ready exposure checklist — flagging the specific counterparties, jurisdictions, ownership structures, and transaction types most likely to trigger OFAC, EU, UN, or UK sanctions liability. Replaces gut-feel risk triage with a structured first-pass screen that tells compliance where to focus legal review.
When to Use
Invoke this skill when the user asks to:
- Assess sanctions exposure before entering a new country or region
- Screen a list of customers, suppliers, or partners for sanctions risk
- Evaluate whether a cross-border transaction or deal structure raises sanctions concerns
- Build a baseline sanctions risk map for a company's international footprint
- Prioritize which counterparties or jurisdictions need enhanced due diligence
- Prepare a sanctions risk summary for legal counsel or the board
Inputs Required
Before starting, collect:
- Business description: What the company does, the products/services traded, and industry (2–4 sentences)
- Countries of operation: Where the company sells, sources, ships, or has entities
- Counterparties: Named customers, suppliers, distributors, agents, or partners — with country of domicile if known
- Transaction types: Nature of dealings (sales, procurement, payments, financing, licensing, JVs, logistics)
- Ownership/intermediaries: Any known parent entities, ultimate beneficial owners, or third-party intermediaries in the chain
- Sensitive goods flag: Whether any products are dual-use, defense-related, energy, tech/semiconductors, or financial services
- Home jurisdiction(s): Where the company is incorporated and banks (determines which regimes apply extraterritorially)
If ownership details or UBO information is missing, flag it as a screening gap rather than assuming a clean structure. This is a first-pass risk identifier, not a substitute for name screening against live sanctions lists.
Instructions
Step 1: Establish Regime Applicability
Determine which sanctions authorities have jurisdiction over the company's activities:
- OFAC (US): Applies if there is any US nexus — US persons, USD-denominated transactions, US-origin goods/technology, US financial system touchpoints, or US-owned/controlled entities. USD clearing alone creates jurisdiction.
- EU regimes: Apply to EU-incorporated entities, EU persons, activities within EU territory, and EU-flagged vessels/aircraft.
- UN regimes: Universally binding via member-state implementation — asset freezes and arms embargoes on designated targets.
- UK OFSI: Applies to UK entities, UK persons, and conduct within UK territory (relevant post-Brexit divergence).
State clearly which regimes attach and why, based on the home jurisdiction and currency/goods flows.
Step 2: Jurisdiction Risk Tiering
Classify each country of operation into a risk tier:
- Comprehensive/territorial embargo: Cuba, Iran, North Korea, Syria, and the Crimea/DNR/LNR regions of Ukraine — near-total prohibition, highest tier
- Sectoral / targeted sanctions: Russia, Belarus, Venezuela — restrictions on specific sectors (energy, finance, defense), entities, or activities rather than the whole country
- List-based only: Countries with no country-wide program but with designated SDN/consolidated-list individuals or entities present
- Elevated-diligence jurisdictions: High-risk for evasion, transshipment, or front companies (common re-export hubs and financial secrecy jurisdictions)
- Standard: No specific program; routine diligence
For each country provided, assign a tier and note the specific program driving it.
Step 3: Counterparty Exposure Analysis
For each named counterparty, evaluate exposure across these vectors:
- Direct listing risk: Could the entity or its principals be a designated party? Flag for live-list name screening.
- 50 Percent Rule exposure (OFAC): Is the entity potentially owned 50%+ in aggregate by one or more blocked persons? Ownership screening required even if the entity itself is not listed.
- EU "control" test: EU rules extend to entities owned or controlled by designated persons — flag opaque ownership.
- Sectoral overlap: Does the counterparty operate in a sanctioned sector (e.g., Russian energy/finance/defense)?
- Intermediary/agent risk: Third parties, brokers, and freight forwarders that could obscure the true end-user or destination
Rate each counterparty High / Medium / Low exposure with the specific driver named.
Step 4: Transaction & Goods Vector Screen
Assess how the nature of the dealings compounds risk:
- End-use / end-user risk: Diversion to military, WMD, or prohibited end-uses
- Dual-use and export-controlled goods: Items subject to EAR, EU dual-use regulation, or Wassenaar controls layered on top of sanctions
- Payment channel risk: USD clearing through US correspondent banks, transactions routed through sanctioned financial institutions, or crypto/alternative rails used to evade
- Transshipment / re-export risk: Goods routed through elevated-diligence hubs toward embargoed destinations
- Facilitation risk: Non-US persons facilitating US-person prohibited conduct, or "US person facilitation" of otherwise-permitted foreign dealings
Step 5: Build the Prioritized Exposure Checklist
Consolidate findings into a ranked checklist. Rank by a combined severity of (a) regime penalty exposure and (b) likelihood the vector is live. Each item states: the exposure, the regime(s) implicated, why it ranks where it does, and the specific review action required (e.g., "run UBO screen," "obtain end-user certificate," "seek OFAC-licensable analysis from counsel").
Step 6: Flag Screening Gaps and Recommend Next Steps
Explicitly list what could not be assessed from the inputs (missing UBO data, unnamed sub-distributors, unknown payment routing) and specify the concrete diligence step to close each gap.
Output Format
- Structure: Regime applicability statement → jurisdiction risk tiers → counterparty exposure table → transaction/goods vectors → prioritized checklist → screening gaps
- Length: 900–1,300 words
- Format: Structured document with a counterparty exposure table and a numbered, ranked exposure checklist
- Sections: Regime Applicability · Jurisdiction Risk Tiering · Counterparty Exposure · Transaction & Goods Vectors · Prioritized Exposure Checklist · Screening Gaps & Next Steps
- Tone: Trade compliance counsel — precise, cautious, non-alarmist; names specific regimes and rules; never gives a definitive legal clearance
Quality Checklist
Before delivering output, verify:
- [ ] Regime applicability is reasoned from the home jurisdiction, currency, and goods flows — not assumed
- [ ] Every country provided is assigned a specific risk tier with the program named
- [ ] Every named counterparty has a High/Medium/Low rating with a named driver
- [ ] The 50 Percent Rule / EU control test is explicitly addressed for entities with unclear ownership
- [ ] The exposure checklist is ranked by severity, not listed arbitrarily, and each item names a review action
- [ ] Screening gaps are stated openly, and the output does not claim to clear any party
Notes
- This is a risk-identification and triage tool, not legal advice or a live sanctions-list screen — every flagged party must still be run against current OFAC SDN, EU consolidated, UN, and UK OFSI lists.
- The most commonly missed exposure is indirect ownership: an unlisted counterparty majority-owned by blocked persons is itself blocked under OFAC's 50 Percent Rule. Push hard on UBO clarity.
- USD in the transaction chain is the single most common way non-US companies pull themselves into OFAC jurisdiction — always trace the payment rail.
- Sanctions programs change frequently; treat any tiering as accurate only as of the current program status and advise re-screening before execution.
How to use this skill
This file is a Claude Code skill in Anthropic's standard format — markdown with YAML frontmatter at the top.
Installing in Claude Code:
~/.claude/skills/<folder-name>/SKILL.md— auto-loads in every session anywhere on your machine (recommended for skills you'll use across multiple projects)<your-project>/.claude/skills/<folder-name>/SKILL.md— auto-loads only when working in that project (recommended for project-specific skills)
Restart Claude Code or open a new session to register.
Using in Claude.ai, ChatGPT, Gemini, or other AI tools:
- Drag this file into a new chat, or copy and paste its contents
- Send your task or request as your next message — the AI will apply the skill where it fits
For Claude Code skill details: https://docs.anthropic.com/en/docs/claude-code/skills