Scenario: Agent Pays Russian Government Entity
The state-entity scenario - government exposure runs through supply chains.
The setup
Your agent's supply chain includes a vendor that is a Russian state-owned entity - or is owned 50%+ by a designated official.
The gap
- Name-only screening may pass an indirect subsidiary
- State-linked entities are in scope under the Russia program
- One payment = one violation
With screening
- The screen matches the designated entity or its owner
- The payment is blocked before sign
- Ownership analysis confirms the state link
- Results logged with the list version
The takeaway
Government-entity exposure runs through supply chains. Screen the counterparty, its owners, and its state-linked status.