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AMLEGALS / Regulatory & Compliance / Sanctions and Trade Compliance India for Foreign Companies
Regulatory and FEMA compliance

Sanctions and Trade Compliance India for Foreign Companies

Sanctions and trade-compliance alignment for foreign companies operating in India.

Strategic context

The issues that decide the outcome

A foreign company operating in India sits at the intersection of two sanctions worlds. It must comply with the sanctions India itself implements, principally UN-mandated measures and country-specific trade restrictions, and it must simultaneously honour the OFAC, EU, and UK sanctions that bind its parent and its banking relationships. These regimes do not always align, and an India transaction that is lawful under Indian law can still breach a parent-level sanctions obligation or trigger a correspondent-bank refusal.

We build a single compliance framework that satisfies both layers, screen counterparties and ultimate beneficial owners against the relevant lists, and advise on payment routing where banks apply conservative de-risking. Where a transaction touches a sanctioned nexus, we assess licensing, wind-down, and exit options so the India operation does not expose the global group.

Workstreams

How AMLEGALS acts

01

Dual-regime framework

Designing a sanctions and trade-compliance framework that satisfies both Indian obligations and the parent OFAC, EU, and UK requirements.

02

Counterparty screening

Implementing sanctions, denied-party, and ultimate-beneficial-owner screening across customers, suppliers, and investors.

03

Payment and banking risk

Advising on cross-border payment routing and correspondent-bank de-risking so legitimate transactions are not frozen or returned.

04

Trade-control alignment

Aligning import and export activity with FTDR Act restrictions and country-specific trade controls.

05

Transaction risk assessment

Assessing specific deals, counterparties, or jurisdictions for sanctions nexus before the group commits.

06

Incident response and wind-down

Managing a positive screening match or a changed sanctions designation, including licensing, freezing, and compliant wind-down.

Answers

Frequently asked questions

01Do US sanctions apply to an Indian subsidiary of a US company?

OFAC primary sanctions generally reach US persons and, for certain programmes, entities owned or controlled by them. An Indian subsidiary of a US parent must therefore manage both Indian law and the parent US obligations, which is why a dual-regime framework is essential.

02India does not implement OFAC sanctions, so why worry about them?

Because the banks that clear the group payments, the parent, and the auditors all do. A transaction lawful in India can still be blocked by a correspondent bank or breach a parent-level control, so the global exposure has to be managed even where Indian law is silent.

03What sanctions does India itself enforce?

India implements UN Security Council sanctions through domestic law and maintains its own trade restrictions on specified countries and goods. These are the binding Indian obligations, layered under the broader group-level regimes.

04Does an initial discussion create a lawyer-client relationship?

No. No engagement is treated as accepted until conflicts, scope and terms are confirmed in writing. An initial discussion is confidential and is used only to understand the matter and assess fit.

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Business contact details are used only to respond to this request. No lawyer-client relationship arises until conflicts, scope and terms are agreed in writing.