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 Corporate Sanctions Compliance Entity (CSCE) Certificate fills this gap.
How it works
CSCE is a questionnaire-based certification platform, but it goes far beyond simple self-certification.
Throughout the certification process, your company is guided by recognised sanctions experts as well as legal and compliance advisors before you submit your answers to the questionnaire. We understand that sanctions are not easy matters, and we do not leave you to navigate the process alone.
Engage various departments
Certification begins with your request to join the CSCE programme. After an initial consultation, you’ll receive access to the secure online questionnaire. Guided by CSCE experts, your team will gather input from relevant departments, ensuring a complete and accurate compliance profile.
Once reviewed, your company will be awarded one of the two certification levels — CSCE-EU “Conformity” or CSCE “Observatory”. Both levels confirm to regulators and stakeholders that your company has taken proactive steps to meet due diligence standards in the sanctions context.
Collaborative effort
We know compliance is a collaborative effort. The CSCE platform enables you to engage various departments within your company to gather all the data needed to gain a complete picture of your organisation’s sanctions compliance framework.
It allows you to request input from specific team members — for example, in tax, logistics, sales, or purchasing — on aspects that are particularly relevant from a sanctions perspective.
European-Level Support
Our platform addresses matters at the European level.
We are fully prepared to conduct audits and provide certification services to companies across Europe, regardless of their location.
With a flexible, cross-border approach, we ensure seamless coordination and compliance with European standards, offering consistent support to businesses operating in any EU 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.
Counsil Oversight
Independent board of practitioners and experts that ensure:
- Competence
- Oversight
- Practicality
- Guidance
- Impartiality
- Transparency
Platform Methodology
Three Components:
1
Questionnaire: Covers key focus areas such as risk mapping, procedures and tools.
2
Documentation: Review of key documents, incl. compliance policies, contractual clauses and related materials.
3
Interviews: Discussions with stakeholders on the practical aspects of sanctions compliance.
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 corporatesanctionscertification.org, 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.
