Sanctions compliance has evolved far beyond simple list screening. In a new article for the International Compliance Association, “Studies in Ownership and Control,” John Gibson examines two recent English Commercial Court decisions that illustrate the complex judgments companies must now make when assessing sanctions risk. Looking at EuroChem v Société Générale and Tonzip Marine v 2Rivers, John explores how courts evaluate ownership, control, and influence—sometimes through exhaustive forensic analysis and other times through the lens of reasonable commercial judgment made under uncertainty. For banks, traders, shipowners, and other global businesses, the takeaway is clear: effective sanctions compliance today requires looking well beyond formal ownership structures and being prepared to explain the reasoning behind critical decisions.
