Our commitment
Mallesons is committed to complying with applicable sanctions laws and to conducting our business in a manner that upholds the integrity of the legal profession, our clients, the broader community and the international legal and financial system.
Sanctions laws may restrict or prohibit us from providing legal services in certain circumstances, dealing with particular persons or entities, making particular assets or funds available, or conducting matters, transactions or activities that involve particular jurisdictions, sectors or counterparties. These legal obligations can stem from Australian sanctions laws or other applicable international sanctions regimes.
Our approach
We have comprehensive policies, procedures, systems and controls designed to identify, assess, manage and mitigate sanctions risk across our firm.
Key elements of our approach include:
- maintaining risk assessment frameworks and processes to identify and assess sanctions risk associated with our clients, matters and transactions
- conducting due diligence on our clients, matters and other entities
- screening of clients and other entities against applicable sanctions lists
- maintaining review and escalation processes for matters involving higher risk jurisdictions, sectors, entities, ownership structures or payment flows
- training our people on sanctions obligations, their individual responsibilities and escalation requirements
- providing governance and senior-level oversight of sanctions-related risks, issues and controls.
Mallesons may, on a case-by-case basis, request additional information to help us understand how our clients and their transactions interact with sanctions laws. We need this information in order to safely offer services, and to help us comply with legal obligations.
Where sanctions considerations arise, we may escalate the matter internally for review or apply enhanced controls in connection with the provision of our services.
Consistent with sanctions law requirements and our internal policies, circumstances may arise where we decide, or where we may be required, to cease acting or to decline to accept instructions.
Changes to our approach
Sanctions laws and regulatory expectations may change over time. As such, we may update our sanctions compliance approach, policies and controls from time to time to reflect changes in applicable sanctions regimes, laws, regulatory expectations and our internal risk assessments.
For further information or questions, please contact Matthew Swinn, Managing Partner - Practice Excellence - [email protected].