Updated August 23, 2026
SRV-BA-SN
Sanctions / Compliance / Asset Recovery
BRIDGES checks the sanctions status of the client, the company and connected persons, analyses the grounds of the restriction and determines which lawful mechanisms are available in the relevant jurisdiction.
We handle matters involving false positives, designation, review of restrictions, licensing of specific transactions, banking blocks and frozen assets.
Every matter starts by establishing the applicable sanctions regime, the factual reason for the restriction and the authority empowered to decide the particular question.
Check→Grounds→Case→Delisting
ConfidentialSeveral jurisdictionsLawful mechanisms only
Your situation
At this stage a description of the situation is enough. The document list is defined after the initial assessment.
Initial qualification
The problem comes from a false positive, automated screening, outdated data or internal bank compliance. We check the sanctions lists, identifying data, ownership structure and the reason for the alert, then prepare a position for the bank or counterparty.
We establish the applicable sanctions regime, the authority, the grounds of the listing and the available review procedures: reconsideration, variation, revocation, delisting or judicial challenge.
We check who blocked the asset, on what grounds, where it is legally located and whether a licence, authorisation, derogation, confirmation of status or a decision of the competent authority is required.
A name, a company or an asset appearing in a screening system does not yet explain the legal reason for the restriction.
To build the right strategy it is necessary to establish:
Practice
We screen individuals, companies, beneficial owners, directors, partners and the ownership structure against the applicable sanctions regimes and related compliance risks.
We analyse the grounds of the listing, the factual basis, identifying information, ownership & control and the available review or removal procedures. OFAC, for example, provides a formal administrative reconsideration procedure for persons and property on US sanctions lists.
OFAC · FAQ 897We establish whether the applicable regime allows a specific transaction under a licence, authorisation, derogation or another mechanism provided by law, and support the preparation of the application.
OFSI · UK financial sanctions guidanceWe analyse why funds, securities, real estate or other assets have been blocked and determine the lawful route to their release or permitted use.
Jurisdictions
EU regulations, national competent authorities, derogations and authorisations.
SDN and other OFAC programmes, reconsideration, delisting, licensing and blocked property.
UK designations, licensing, variation, revocation and engagement with OFSI.
UN Security Council sanctions regimes and the procedures they provide.
Swiss sanctions measures and the procedures of the relevant authorities.
Where required we bring in local counsel in the relevant country.
BRIDGES coordinates the matter but does not replace local counsel where national law requires their involvement.
Review / Delisting
Being on a sanctions list does not always mean that no legal review mechanism exists. Depending on the regime the following may apply:
administrative reconsideration · delisting · variation · revocation · judicial review · court challenge · correction of identifying information · reconsideration based on changed circumstances
The route differs from regime to regime. In the US it may be an OFAC petition or licensing process, in the United Kingdom a variation or revocation, and UN regimes have their own delisting procedures. BRIDGES first establishes the regime and the applicable process, then builds the position and the evidence.
In the US a delisting petition may be filed with OFAC, including through a representative. A repeat request after a refusal is also possible where new arguments or evidence exist.
OFAC · Filing a petition for removalIn the United Kingdom a designated person or their representative may request a variation or revocation of the designation.
GOV.UK · Making a sanctions challengeIndividual UN sanctions regimes have their own delisting procedures.
UN Security Council · DelistingPreparation
We determine which sanctions rule applies and which authority took the decision or controls the restriction.
We analyse the grounds of the listing, the identifying information and the public and available materials.
Ownership structure, control, business relationships, corporate history and changed circumstances.
Delisting, reconsideration, variation, licence, authorisation, correction, judicial review or another route provided by law.
Corporate, banking, financial, contractual and other documents supporting the facts relied on.
Filing, responses to further requests, work with local counsel and coordination of the next stage.
The facts, the ownership structure and the applicable regime define the procedure that follows.
Frozen Assets
The fact that an asset is frozen does not explain why it was blocked or which mechanism may apply. OFAC, for instance, explains that blocked property is frozen but title does not normally pass to the state. OFSI likewise states that a UK asset freeze does not change ownership or confiscate assets.
First it is necessary to establish:
Bank accounts and payments.
Shares, bonds, ETFs and other instruments.
Assets held with a broker or financial institution.
Custody chains running through international infrastructure.
Corporate interests and the restrictions attached to them.
Assets whose disposal is restricted by a sanctions regime.
Structures where ownership and control are the key question.
Digital assets held with a regulated intermediary or other infrastructure.
The same asset may pass through a bank, a broker, a custodian, an international depositary and local infrastructure at the same time.
The procedure depends on where exactly the restriction arose and which authority has the power to lift it or permit the transaction.
Custody chain
There is no universal release mechanism. The exact place of the restriction, the applicable law and the procedural window are established first.
False positive
Here the task is usually not to lift sanctions but to confirm identity, ownership structure and the absence of any link to a designated person. OFAC notes separately that a false positive is not a delisting case and that a different channel exists for such situations.
The cause may be a matching name, transliteration, the same date of birth, outdated compliance data, incorrect ownership information or adverse media.
OFAC · FAQ 897Ownership & Control
Under some sanctions regimes the restrictions extend not only to the listed person but also to companies or assets that they own or control.
So we review
The UK sanctions framework, for example, extends restrictions to certain unlisted entities owned or controlled by a designated person.
OFSI · UK financial sanctions guidanceEach case is assessed under the rules of the particular regime. A corporate chart alone does not answer the question of whether restrictions apply, and formally reducing a shareholding is not a way around them.
Licensing
Sometimes the objective is not removal from a sanctions list but permission for a specific transaction. Depending on the regime this may concern:
BRIDGES analyses the grounds, identifies the competent authority, builds the evidential position and coordinates the application with local counsel where their involvement is required.
OFSI expressly provides a licensing framework for acts that would otherwise breach financial sanctions.
OFSI · UK financial sanctions guidanceBanking Remediation
Even after a false positive has been corrected, a licence obtained, a sanctions status changed or an asset released, the bank may require an updated compliance package.
Deliverables
What you receive depends on the matter. Deliverables may include:
Sanctions & Asset Recovery
Legal Assessment & Action Plan
The exact scope depends on the jurisdiction and the legal task. BRIDGES does not replace local counsel where the law requires their involvement.
How we work
BRIDGES does not take part in circumventing sanctions and does not offer arrangements designed to hide the true owner, control or the origin of assets.
We do not
We do
Cost
After the initial assessment we fix the scope, the stages and the BRIDGES fee. The costs of local counsel, state authorities and other external specialists are stated separately.
How it works
We identify the client, the asset, the ownership structure and the nature of the restriction.
We establish the sanctions regime, the competent authority and the legal basis.
We review owners, control, group companies and connected persons.
Designation, block, false positive, banking compliance or asset freeze.
We determine the permissible mechanism: correction, delisting, reconsideration, licence, authorisation, challenge or another route provided by law.
We collect corporate, banking, financial, contractual and other supporting material.
We coordinate the filing, local counsel, responses to requests, engagement with banks and the steps that follow the decision.
The timelines of state authorities, banks and financial institutions are outside the control of BRIDGES and are assessed separately.
A sanctions matter needs a precise legal position and evidence, not a general explanation of the situation.
FAQ
Some regimes provide procedures for review, delisting, variation, revocation or judicial challenge. Whether this is available, and how it works, depends on the particular regime, the grounds of the designation and the facts of the case. The applicable law and the available procedure have to be established first.
Sometimes, yes. It depends on who froze the funds, where they are held, which sanctions regime applies and whether a licence, authorisation or another decision of the competent authority is required.
Yes, matters can concern securities, brokerage accounts and international custody infrastructure. The custody chain and the level at which the restriction arose have to be established first.
OFAC provides reconsideration and removal procedures. The outcome depends on the grounds of the listing and the evidential position presented. BRIDGES does not guarantee an OFAC decision.
In some cases, yes, where the applicable procedure allows a repeat request or new facts and circumstances have arisen.
The UK sanctions framework provides for variation, revocation and other forms of review. The exact route depends on the designation and the applicable legislation.
No. The decision is taken by the competent authority or a court. BRIDGES analyses the grounds, prepares the position and supports the procedure provided by law.
Identity, the underlying facts, the ownership structure and the absence of any link to a listed person have to be confirmed. A documented compliance position is prepared for the bank or counterparty.
Not necessarily. An asset freeze and confiscation are different legal regimes. Title and the ability to deal with the asset have to be analysed under the applicable law.
INITIAL ASSESSMENT
We will design a solution for your case, choose the country and the right status, and take the whole process through to the result.
