Sanctions & Trade Compliance Certification for Companies

Strengthen your company’s credibility and demonstrate your commitment to international compliance standards by becoming a CSCE – Certified Sanctions Compliance Entity.

Benchmark Report & Certification

Platform authors:

Sanctions advisory from the EU perspective:
Rymarz Zdort Maruta lawyers & Et Cetera

Project subject-matter oversight from the U.S. side: Baker Hostetler Law Company

About CSCE Certificate

The European Union has introduced an unprecedented number of sanctions, creating major compliance challenges not only for companies but also for National Competent Authorities (NCAs) tasked with assessing sanctions due diligence. With the adoption of the EU Sanctions Criminalisation Directive, the stakes for companies have never been higher — breaches can now trigger harmonised criminal liability across Member States, including for negligence. The absence of an EU-wide benchmark makes this assessment even harder. The Certified Sanctions Compliance Entity (CSCE) Certificate fills this gap.

Quality Board

Anna Partyka-Opiela, PhD

Attorney-at-law, Doctor of Laws; partner and head of the Compliance, Forensic, and ESG practices at RZM. She has extensive experience advising on sanctions and over 15 years of experience in compliance audits, forensic audits, and projects focused on fraud and abuse risk management.

Marcin Łukowski, PhD

International sanctions lawyer, Doctor of Laws, specializing in global trade compliance, sanctions, export controls, and AML/KYC. Certified Global Sanctions Specialist (CGSS) from ACAMS and Associate Fellow at the Royal United Services Institute (RUSI).

Artie McConnell

Partner and co-leader of BakerHostetler’s National Security Investigations and Litigation Task Force. A decorated former federal prosecutor who led DOJ sanctions and export control cases and earned top DOJ honors, including the John Marshall and Distinguished Service Awards.

Jeff Nielsen

Sanctions and export controls counsel with 20+ years of experience across law firms and in-house roles, advising U.S. and EU businesses. He has worked with a global shipping giant and Scandinavia’s largest bank, and served as a foreign policy advisor in the U.S. House of Representatives

Jan Dunin-Wasowicz

Partner and co-founder of Bennink Dunin-Wasowicz, a European law firm in Paris and Amsterdam focused on sanctions, export controls, and trade compliance. Admitted to the Paris, New York, and D.C. bars, he advises on regulatory matters, investigations, and international disputes. Recognized in GIR 40 under 40 (2024) and by Best Lawyers for EU law, he previously co-chaired the sanctions and AML practice at a New York firm. He also hosts the podcast This Month in EU Sanctions.

Erika Trujillo

NY-qualified lawyer, Co-founder & Director at SEIA GmbH, a compliance tech firm delivering risk management solutions with advanced analytics. Formerly at a Big Four firm, advising on export controls, sanctions, and trade compliance tech. Past roles include EMEA Trade Controls lead at a global automotive supplier and trade specialist at the U.S. Department of Commerce.

How it works

1. Certification begins with your request to join the CSCE. After an initial consultation, you’ll receive access to a secure online questionnaire. Guided by CSCE experts, your team will gather input from relevant departments, ensuring a complete and accurate compliance profile.

2. Based on the information provided in the questionnaire and obtained during discussions, you will receive a comprehensive report outlining the state of your compliance system, along with concrete recommendations.

3. Your company will also be awarded one of two certification levels: CSCE-EU “Approved” or CSCE “Pending”. Both levels demonstrate to regulators and stakeholders that your company has taken proactive steps to meet due diligence standards in the context of sanctions compliance.

Expert guidance

Throughout the certification process, your company is guided by recognized sanctions experts as well as legal and compliance advisors before you submit your answers to the questionnaire. We understand that sanctions are complex matters, and we will not leave you to navigate the process alone.

Collaborative effort

We know compliance is a collaborative effort. The CSCE platform enables you to engage various departments within your company — for example, those in finance, sales, or purchasing — to gather all the data needed for a complete picture of your organization’s sanctions compliance framework.

European-Level Support

CSCE monitors compliance with European sanctions regimes.

We are fully prepared to conduct audits and provide certification services to companies across the world, regardless of their location, that wish to remain compliant with EU standards.

With a flexible, cross-border approach, we ensure seamless coordination and compliance with European standards, offering consistent support to businesses operating in any jurisdiction.

Two levels of certification:

CSCE-EU “Pending” (Waiting Room)

Granted when the process identifies certain deficiencies. This status is still valuable, as it demonstrates that the company has made the effort to audit itself. Depending on the company’s needs, this status may remain confidential while work with CSCE experts and partners continues to enhance the company’s internal processes and achieve full certification.

CSCE-EU “Approved”

Awarded when the company passes the questionnaire and is assessed as meeting all compliance criteria. The company receives a certificate that can be displayed on its website and used in communications with national competent authorities to confirm steps undertaken to meet compliance requirements. The company may also be listed on the CSCE website among CSCE-Approved companies.

Certifying EU compliance – mindful of U.S. sanctions impact

CSCE recognises that in today’s interconnected markets, compliance cannot stop at EU borders. While the certificate is rooted in EU law and sanctions practice, the questionnaire recognises the extraterritorial reach of U.S. sanctions, identifies potential U.S. nexus in an EU company’s operations, and helps protect the EU entity by reducing the risk of inadvertent violations of US law.

Overview

Purpose

1

To create an EU/US benchmark for sanctions/export control and trade compliance.

2

To provide actionable insights to allow businesses to align with best practices.

3

To offer certification to validate compliance frameworks.

Scope

1

Comprehensive coverage of EU sanctions regimes (including, but not limited to, Russia, the Middle East, China and Africa), taking into account U.S. legal requirements. 

2

Suitable for both SMEs and multinational corporations across high-risk and low-risk sectors, with a focus on size and sector-specific risks. 

Market Risks & Threats

  • Reputational & image risks in the case of non-compliance. 
  • Financial penalties – up to 5% of annual turnover. 
  • Criminal, administrative and/or civil liabilityfor the company and/or individuals. 
  • Failure to meet contractual requirements –possibility of the termination of contracts.

Participation Incentives

Confidentiality

Anonymous or credited contributions.

Exclusive Access

Access to a closed community and benchmarking.

Recommendations

Tailored recommendations post-report.

Great Value

Review, certification & monitoring all in one.

Why It Matters
Value of Participation

  • Benchmark your compliance programme against industry peers.
  • Gain strategic insights and tailored recommendations.
  • Join industry dialogue & influence future standards.
  • Obtain exclusive CSCE certification.
  • Shape global compliance standards.

Quality Board Oversight

CSCE framework is developed with an independent board of practitioners and experts that ensure:

  • Competence
  • Oversight
  • Practicality
  • Guidance
  • Impartiality
  • Transparency

Contribution

Rymarz Zdort Maruta

Anna Partyka-Opiela and Jan Bednarski offer deep expertise in implementing EU-level compliance and governance standards.

As head of Compliance, Forensic, and ESG at Rymarz Zdort Maruta, Dr. Partyka-Opiela combines legal knowledge with practical experience in audits and compliance structures. She ensures platforms meet EU certification and regulatory requirements. Clients benefit from the firm’s strong reputation, a clear understanding of EU supervisory systems, and consistent support across sectors such as banking, pharma, energy, and industry.

Et Caetera

Dr. Marcin Łukowski, founder of Et Caetera—a boutique consultancy focused on international sanctions—brings in-depth regulatory and strategic expertise on EU sanctions.

A recognized expert with both academic and practical experience, he developed a methodology for sanctions risk assessment and actively contributes to the EU SanctionsHelpdesk and RUSI His innovative tools, including a dynamic sanctions risk assessment form available on www.etcaetera-compliance.com, support clients in managing compliance and strategic risks amid geopolitical uncertainty.

Baker Hostetler

Artie McConnell, a former U.S. federal prosecutor and expert in sanctions, cybercrime, AML, and export control, brings U.S.-law expertise to the project through his work with BakerHostetler, a leading firm in national security and regulatory risk.

His background offers valuable insight into enforcement from a prosecutorial perspective, enriching CSCE’s assessments for clients exposed to U.S. jurisdiction. Clients benefit from a deeper understanding of U.S. regulatory scrutiny and gain transatlantic risk analysis on issues like sanctions divergence, extraterritoriality, dual-use compliance, and data transfer.

To get certified, contact us at contact@sanctionscertificate.eu

Disclaimer: The CSCE Certificate does not certify individual employee conduct or guarantee the absence of sanctions violations. It is not issued by the EU or any EU institution, agency, or body. It reflects that, based on information provided to CSCE and the independent assessment of qualified experts and legal practitioners, your organization has implemented a sanctions compliance program aligned with prevailing market standards and demonstrating enhanced due diligence aimed at meeting EU sanctions requirements. CSCE’s assessment is limited to the scope and documentation reviewed.