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Nikunj Agarwal

Associate in the Dispute Resolution Practice at the Mumbai office of Cyril Amarchand Mangaldas. Nikunj focuses on white-collar crimes, investigations, and disputes. He can be reached at nikunj.agarwal@cyrilshroff.com

Sanctions Compliance Beyond the 50% Rule: A Practical Guide for Indian Businesses

Summary: The 50% ownership rule has always been the cornerstone of sanctions compliance offering apparent certainty to entities navigating complex cross-border transactions. However, in recent years, global regulators have started looking beyond the ownership percentage, scrutinizing effective control and influence to determine sanctions exposure. This piece examines the evolving sanctions landscape across the US, UK & EU and provides Indian businesses with a practical, risk-based compliance framework to align with international enforcement expectations.

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