Sectors / 06
Cross-border trade & sanctions
We test the counterparty, owner, destination and route behind a trade before you commit to it, and keep the evidence that you did.
What is changing, and what it means for you.
What is changing
- US export rules are moving from listed names to ownership: subsidiaries 50% owned by listed parties are set to be treated like their owners.
- Diversion through third countries is a priority for UK, EU and US enforcement.
- Large UK organisations can now be prosecuted for failing to prevent fraud by those acting for them.
Who it affects
Exporters of controlled or US-origin items, principals and trading desks moving cargo through third countries, and businesses appointing agents, distributors and partners abroad.
The problem it creates
Screening a name against a list no longer shows the risk. The exposure sits in who owns the customer, where the goods go next, and who acts on your behalf.
What Meridian does
We trace ownership to the top, test destination and route, and record what was checked and when, so a decision can be defended later.
Different businesses, different first steps.
Each starts with a defined scope and a fixed fee, set out in writing within 24 hours.
If you are
Exporting controlled or US-origin items
Your customers pass list screening, but you do not know who owns them.
You receive: Each customer and consignee traced to its ultimate owners, with listed ownership and aggregated holdings flagged.
If you are
Moving cargo through third countries
A deal is about to close and the counterparty, vessel or route is not fully known.
You receive: A screen in five working days, or a fuller review in ten, before you commit.
If you are
Appointing agents, distributors or partners
You need reasonable procedures for the people who act for you abroad.
You receive: Each third party’s identity, ownership and standing verified, and recorded in a form you can show a regulator.
Not sure which fits? Describe the situation
Start today at a fixed fee.
Paid upfront, delivered to a fixed scope, and credited in full against any Meridian engagement within 60 days.
If you are about to commit to a supplier
Supplier Risk Check
One supplier screened for ownership, sanctions and listed-entity exposure, including the UFLPA Entity List, set out in a two-page note.
If a customer has sent an EUDR or CBAM questionnaire
Customer Questionnaire Response
We complete one questionnaire, up to 40 questions, from the documents you supply, with the evidence behind each answer.
If your EU customer wants deforestation evidence
EUDR Supplier Evidence Pack
Supplier guide, declaration template, plot and geolocation data sheet, evidence index and model questionnaire answers.
Payments are processed securely by Stripe. For business customers; no VAT is charged. Terms of sale
Three questions, answered with evidence.
010203What we read.
- VesselIMO number, flag, ownership and AIS history.
- CargoProduct origin, including EU Regulation 833/2014 Article 3ma.
- PartiesOwner, manager and charterer, with the 50 per cent ownership rule applied.
Standards & regulation.
The frameworks we work to in this sector.
UK autonomous sanctions framework.
Licensing, ownership and control.
Civil penalties for sanctions breaches.
SDN list and the 50% rule.
Statutory basis for US sanctions.
EU Russia restrictive measures.
CDD, EDD and PEPs.
International CDD standard.
Failure to prevent bribery.
Failure to prevent fraud.
US anti-bribery.
Anti-bribery management.
Supply chain security.
Trusted trader programmes.
Data protection in diligence.
What we screen against.
Every counterparty, owner and director.
UK financial sanctions.
UN Security Council list.
Specially Designated Nationals.
EU consolidated list.
Export-restricted parties.
Denied and unverified parties.
ITAR debarred parties.
Debarred firms and individuals.
Registry, officers and PSC.
Politically exposed persons.
Reputational and legal exposure.
Related thinking.
Recent notes that bear on this sector.
Failure to prevent fraud, one year on. What “reasonable procedures” means for your third parties
Since 1 September 2025, large organisations are liable for fraud committed by employees, agents and subsidiaries for their benefit. The main defence is reasonable procedures, and third parties are where most organisations are thinnest.
Over 670 listed tankers. Screen the shadow fleet by IMO number, not by name.
The EU has now listed more than 670 vessels in Russia’s shadow fleet, and the UK close to 600. Coastal states are boarding ships that fly false flags. For traders, charterers and buyers, the risk sits in the ship as much as the counterparty.
The US “affiliates rule” is paused, not gone. Check who owns your customers.
Washington’s pause on the BIS affiliates rule was due to end on 9 November and is expected to follow the US–China truce to 10 January 2027. When it returns, companies 50% or more owned by listed parties face the same restrictions as their owners, whether or not they appear on any list.