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In April 2018, the US sanctioned seven Russian tycoons and their businesses. A month later, Trump ordered the reimposition of sanctions on Iran, threatening the continued implementation of the 2015 JCPOA. In a bid to safeguard their interests, some have sought to conceal sanctioned beneficial owners or establish ostensibly unconnected affiliates. But with the threat of secondary sanctions looming, how can your business protect itself from unknowingly engaging with such counterparties exposed to sanctions?