When a jurisdiction is comprehensively restricted, the compliance question answers itself. Easing sanctions removes the prohibition and leaves the risk, and it does so at exactly the moment your commercial teams have a reason to move.
Restriction is, from a risk perspective, a gift. A comprehensive sanctions program does the hard thinking for you. There is no counterparty analysis to run, no ownership chain to unpick, no judgment call about a subcontractor two tiers down, because the answer at the top of the tree is no. Abstention is a control, and it is the only control that has never failed.
Relief takes that away. It does not reduce the underlying risk in the market, which is a function of governance, conflict history, informal power, and the durability of institutions, none of which change on the date an executive order is signed. What changes is that your commercial teams now have a legal basis to proceed, a first-mover argument, and a board that has read the same reconstruction headlines they have.
Syria in 2025 is the live example. The comprehensive United States program is gone. What remains is a lattice of targeted designations covering Assad-linked actors, human rights abusers, narcotics traffickers, terrorism-related actors, Iran-linked parties, and others. Every one of those requires you to know precisely who you are dealing with, in a jurisdiction where knowing precisely who you are dealing with is structurally difficult.
The prohibition was the easy part. What replaced it is a requirement for judgment, exercised at speed, in a market designed to defeat it.
Why the Risk Goes up Rather Than Down
Three things happen simultaneously when a market opens, and they compound.
The first is that commercial urgency arrives before compliance capability does. Reconstruction, energy, ports, logistics, telecommunications, and healthcare opportunities are visible immediately. The diligence infrastructure needed to assess them is not, and it takes quarters to build in a jurisdiction with no reliable registry, contested records, and a decade of undocumented ownership transfers. The gap between when the opportunity appears and when you can responsibly assess it is where the losses live.
The second is that relief is granular and marketed as binary. Internal communication compresses. What the legal team said was a partial easing subject to residual designations becomes, three forwards later, Syria is open. Nobody lied. The nuance simply did not survive the retelling, and the commercial team is operating on the compressed version.
The third is that the counterparties who move fastest into a newly opened market are, on average, the ones you least want. Legitimate operators with reputations to protect wait for clarity. The ones waiting at the border with a structure already built have usually built it for a reason.
What Screening Does Not Tell You
A clean screening result in a post-relief jurisdiction is close to uninformative, and treating it as assurance is the single most common failure pattern.
- Designations attach to named persons. Control attaches to relationships. Family networks, nominee arrangements, and informal authority do not appear on a list and are frequently invisible in a registry, particularly one that has been reconstituted after a conflict.
- Trade controls are consistently less mature than financial controls. The UK Financial Conduct Authority has said so directly. Goods classification, end-use review, and diversion risk are where the exposure has migrated, and they are handled by operations rather than compliance in most organizations.
- The risk is usually not your counterparty. It is your counterparty’s freight forwarder, customs broker, security provider, or site-level subcontractor, selected locally, after signature, by someone who was never briefed on any of this.
- Jurisdictional positions diverge. The U.S., the UK, the EU, the UN, and local law will not align, and a transaction that is clean under one may not be under another. Your exposure is the union of all of them, not the intersection.
The Posture That Works
The organizations that navigate this well share a characteristic that has nothing to do with their screening tooling. They treat market entry as a sequence of gates rather than a decision, and they are willing to stop at any of them.
That means jurisdiction assessment before counterparty work, counterparty intelligence before transaction mapping, transaction mapping before contract negotiation, and contract controls before capital commitment. Each gate can fail the deal. If none of them can, they are not gates, they are documentation of a decision already taken, and everyone involved knows it.
It also means accepting that the answer is sometimes still no. Relief is permission, not endorsement. A market can be legally open and remain a market you should not enter, and the discipline to say so is worth more than any diligence product, because it is the only thing that survives when the diligence comes back ambiguous, which in these jurisdictions it usually does.
The Question to Put to the Board
Not can we do this. That question has a legal answer, and the legal answer has probably changed, which is why the question is being asked. The better question is whether we can evidence how this will be done, by whom, with whose money, through which intermediaries, and under what controls.
If the honest answer is not yet, that is a finding. The pressure to treat it as a delay rather than a finding is what turns an open market into an enforcement matter three years later, when the person who approved it has moved on, and the file has to speak for itself.
Ankura supports market-entry risk assessment, beneficial ownership investigation, sanctions and export-control review, funds-flow analysis, and third-party program design in fragile and post-relief jurisdictions.
© Copyright 2026. The views expressed herein are those of the author(s) and not necessarily the views of Ankura Consulting Group, LLC, its management, its subsidiaries, its affiliates, or its other professionals. Ankura is not a law firm and cannot provide legal advice.
