Mapping a Sanctioned-Country Client's Ownership Chain
Dug into a high-risk Russian entity's shareholding structure to surface the data needed for a safe onboarding decision
Anurag Upadhyay
Analyst at KPMG India
From their time as
Analyst
KPMG India • 2024 - 2026
Overview
Anurag was assigned to a due diligence review of a client based in Russia, a sanctioned jurisdiction that required a higher level of scrutiny than a standard onboarding case. The entity's shareholding information was incomplete, and the risk of proceeding without clarity was significant.
The Story
Anurag was assigned to a due diligence review of a client based in Russia, a sanctioned jurisdiction that required a higher level of scrutiny than a standard onboarding case. The entity's shareholding information was incomplete, and the risk of proceeding without clarity was significant.
He worked alongside his manager to identify the key red flags in the ownership structure before engaging the client directly. The team prepared a structured set of questions targeting the gaps in the shareholding chain and the areas of regulatory concern.
Anurag participated in a direct call with the client, raising the specific questions the team had flagged. The client, initially guarded, agreed to share a detailed information memorandum that had not been provided during the initial onboarding process.
With that document in hand, the team was able to complete the ownership mapping and deliver a risk assessment that gave the client a clear picture of what needed to be resolved before any live engagement could proceed.