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Compliance and investigation

Over the last decades, compliance related crises have shaken confidence in the business sector, both in Norway and internationally. This has resulted in an increased willingness and ability on the part of the authorities to regulate and sanction, as well as a stronger focus on compliance and risk management among businesses.

Thommessen has over time developed extensive compliance expertise and experience, and currently advises a broad range of Norwegian and international businesses on addressing compliance challenges in relation to, for example, anti-corruption, sanctions, export control, human rights, anti-money laundering and terror financing issues.

We assist clients in a number of industries with risk analysis, transaction risk management, managing third party risk via integrity due diligence (IDD), resolution of disputes originating from compliance events, etc. We also have extensive experience in assisting clients with application processes, licence processes and other forms of contact with the authorities.

Our lawyers have extensive crisis management experience, both before an issue enters the public domain and when the authorities come knocking on the door. We often assist companies that are subjected to public inspections or investigations by bodies such as the Norwegian National Authority for Investigation and Prosecution of Economic and Environmental Crime (Økokrim), the Ministry of Foreign Affairs and the Norwegian Police Security Service (PST), and have represented companies indicted in several of the largest Økokrim prosecutions in Norway.

Our compliance team focus on the following four main issues:

  • Money laundering: The money laundering legislation affects clients both inside and outside the financial sector. We find that companies at risk of committing or contributing to money laundering are subject to an ever-increasing scrutiny from state authorities, and such authorities have high expectations to undertakings with regards to routines to identify and prevent such actions. We are well acquainted with money laundering legislation and have extensive experience in advising and developing procedures for the prevention of money laundering risk.
  • Corruption: Worldwide, supervisors prioritize the investigation and prosecution of corruption, also in countries where corruption is widespread. Companies with presence in such countries are particularly at risk, especially if they employ agents, have public customers and suppliers or otherwise have a high level of interaction with the public sector. More stringent requirements are being set towards private actors in order to prevent corruption or complicity in corruption. Thommessen has assisted clients in a number of major corruption cases, and we also have extensive experience in preventing corruption risk.
  • Sanctions and export control: Companies with customers or contacts in areas where sanctions are applied have a particular risk of breaking the sanctions regulations, but such a risk is present for all companies operating internationally. The export control legislation applies to both companies selling defence equipment, and companies selling goods or services with a potential for being used for military purposes such as electronics, PCs, telecoms, sensors, navigation equipment, marine equipment, aircraft, etc. We assist in identifying and managing sanction and export control risks. As the only Norwegian member of the law firm network Lex Mundi, we can seamlessly involve counsellors from other jurisdictions when necessary.
  • General risk management: Thommessen has extensive experience in identifying and managing compliance risk for our clients. We develop compliance manuals specifically tailored to each business and assist with implementation through training programmes, updating of board instructions and other internal guidelines.
What impresses me most about Thommessen is both its expertise and its commitment to providing excellent client service. Client
Chambers & Partners Global, 2020

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