Case study – Assessment of Sanction Exposure and Dual-Use Risks in the Chromium Industry

A European business association engaged our team to conduct a sanction risk assessment of various third parties operating primarily in the metal and chromium industry.

As part of the engagement, we conducted comprehensive background investigations and open-source intelligence (OSINT) research into third-party ownership structures, compliance history, and geographic exposure. This involved analysing corporate hierarchies and producing visual representations of ultimate beneficial ownership (UBO) to uncover potential links to high-risk jurisdictions or sanctioned entities.

In parallel, we carried out an in-depth dual-use product analysis. Third-party product portfolios were reviewed and cross-referenced against the EU Dual-Use Regulation and the US Export Administration Regulations to identify items falling under controlled categories, such as specialised metal alloys, precision tooling, and materials used in aerospace, defence, or nuclear applications. We also assessed end-use and end-user scenarios to evaluate risks related to military or prohibited uses.

The final deliverable included:

• a comprehensive risk report detailing sanction exposure, ownership concerns, and jurisdictional red flags;
• a dual-use product matrix aligning identified goods with relevant control list entries and applicable licensing requirements;
• end-use and end-user risk assessments for products and entities flagged during the review.