What this area covers: sanctions & PEPs in the US
Sanctions & PEPs is one of 6 parts of our “Compliance & AML” practice. It covers the full cycle from initial scoping to operational launch, run by a single named partner from our US practice.
What it is in the US: screening, monitoring and escalation.
How we handle sanctions & PEPs
The “Sanctions & PEPs” project in the US is structured as a 4-stage process run by a single named partner.
Regulatory program drafting, MLRO services, and examination preparation across FINTRAC, FCA, MAS, FIU, and CBUAE frameworks.
The same desk that runs sanctions & PEPs handles your banking, bookkeeping, compliance and — where needed — your wind-down.INNOVA · Operating model
Why the United States
The largest market, deep capital, a choice of state (Delaware, Wyoming, Florida), and a straightforward registration process. We use it for operating companies, reaching US investors, and structures built for venture funding.
A reliable regulatory environment
Banking ecosystem
Corporate tax 21% federal + state taxes
INNOVA represented on the ground
Why INNOVA
Operational differences that hold up on the 2nd, 5th and 10th project — not just at first impression.
One partner — the whole cycle
Registration, banking, tax, compliance, immigration — run by one team from start to finish.
14 years of practice
Working since 2012 through several regulatory cycles — including FATCA/CRS, the tightening of banking, and the introduction of UAE CT.
Regulator-grade documentation
Every output document is ready for audit and investor scrutiny — whatever the size of the deal.
Multi-jurisdiction within the group
Cross-border work is handled inside the group — no chain of external subcontractors.
How the work is structured
A 4-stage process led by a single named partner — from the intro call to the operational hand-over.
Risk assessment
Risk assessment across products, clients and geography
Program development
Manuals, training and control mechanisms
Regulator submission
Submission of the documentation to the regulator
Monitoring
Reviews, audits and keeping the program current
What we need from you · what you get from us
What we need from you to begin — and what you walk away with. We won't pester you with needless questions: we already have most of the answers.
- Activity / sector descriptionstructured
- Customer-base profiledocumented
- Geographic exposuremapped
- Existing controls (if any)stated
- AML/CFT risk assessmentregulator-ready
- Compliance manual + proceduresoperational
- MLRO appointednamed officer
- Training programme (annual)delivered
- Customer DD templatesready to use
- Sanctions/PEP screening liveautomated
Four ways to work together
We don't quote a fixed price without understanding your situation — cost depends on the complexity of your case. Start with an initial call, then we pick the right format.
Intro call
A 30-minute online consultation. We discuss your situation, define the project scope, and propose a structure and timeline.
Written analysis
A written consultation with a full review of the business — tax positioning, structure options, jurisdiction comparison, banking path. Turnaround: 5 business days.
Operating roadmap
For complex situations — multi-jurisdiction structures, regulated activity, founder relocation. A full plan with stages, dependencies, deliverables and timing.
Direct execution
You know what you need — we execute. No advisory mark-up and no discovery phase.
Fill in the questionnaire
Complete the online questionnaire: it creates your account on the portal, where your structure, renewal reminders and documents will live.
Fill in the questionnaire
4 steps · creates an INNOVA portal account · 24h review.
Once you submit the questionnaire we create a portal account. Inside: your live structure, a renewals calendar (annual returns, register updates, tax filings), a document vault (certificates, share register, bank letters), a partner chat and project status. A single place for your entire operational life.
From a client
A review from a client who went through a comparable project. Verified, the engagement is ongoing.
Frequently asked questions
The questions we're asked most often. If yours isn't here, an intro call is the fastest way to get an answer.
Most “Sanctions & PEPs” projects in the United States run 4–5 weeks start to finish. The fastest stage is document filing; the longest is post-registration onboarding (banking, tax registration). A single named partner runs the project throughout.
From US$ 6,500 · program development. The lower bound is for clean, standard profiles; the upper bound is for complex ownership structures, multi-jurisdiction projects or regulated activity. A fixed quote follows a 30-minute scoping call.
In most cases, no. The entire process runs remotely under a notarised power of attorney. A handful of jurisdictions require an in-person visit (typically biometrics for a residence permit) — we plan those as efficiently as possible.
Beneficial Ownership Information (BOI) reporting flows from the Corporate Transparency Act (CTA), but FinCEN's interim final rule of March 26, 2025 sharply narrowed who files: companies formed under any US state law are now fully exempt. The obligation stays with foreign-formed entities registered to do business in a US state. They report to FinCEN the beneficial owners — 25%+ ownership or substantial control — who are non-US persons; US-person owners are not disclosed, and a foreign entity owned entirely by US persons is exempt. Those registered before March 26, 2025 filed by April 25, 2025; later ones have 30 days from when their registration takes effect. Willful non-compliance: $500/day in civil penalty and up to 2 years imprisonment.
Under the CTA, a beneficial owner is an individual who either (1) directly or indirectly owns or controls 25% or more of the company's ownership interests, or (2) exercises substantial control over the company (CEO, CFO, COO, general counsel, or anyone empowered to appoint or remove senior officers or make major decisions). There is no dollar threshold — a 25% LLC member must be reported. Minors, nominees, and certain intermediaries are excluded.
For each beneficial owner: full legal name, date of birth, residential address (not a PO box), and a unique number from a government-issued ID (passport, driver's license) plus an image of that document. The same goes for the company applicant, the person who filed the formation documents. FinCEN issues each beneficial owner a FinCEN identifier: on later filings it replaces re-submitting the full information.
Sanctions & PEPs in other countries
The same service — in every jurisdiction we run. One desk, one standard.
