Sanctions Compliance
Overview
With the Russia/Ukraine crisis bringing huge additional challenges to the management of sanctions risk, now is a time for firms to reconsider how they identify, assess and seek to mitigate these risks.
It is vital to ensure that your firm’s sanctions risk assessment is comprehensive, appropriate and up to date, and that you have the procedures, systems, and expertise to manage this increasingly complex and fast-moving area of risk.
Breaching sanctions is both illegal and likely to lead to significant fines and reputational damage. For financial institutions, sanctions risk is inherent in significant parts of the business, including client onboarding, particularly when identifying ultimate beneficial owners, as well as transaction monitoring and other ongoing reviews.
Board members, other senior management and the Compliance Function must be confident that their firm is managing the specific risks of sanctions in line with regulatory and legal expectations.
This sanctions training course will help your firm to ensure that it has the right approach, skills and knowledge to help to manage sanctions risk at this time of dynamic challenge and complexity.
Learning Outcomes
After attending this sanctions course, participants will be able to:
- Describe the significant global sanctions regimes
- Be able to identify and assess sanctions risk and risk points
- Explain and apply processes for onboarding screening and transaction monitoring
- Identify and act on red flags
Course Details
Session 1
Introduction
- What are sanctions and what do sanctions seek to achieve?
- What happens when you breach sanctions? Actions, penalties and examples
- Understanding the current sanctions environment – what are the implications of sanctions arising under the Russia/Ukraine crisis?
What Sanctions are
- International sanctions
- Commercial and trade sanctions
- Tariff and non-tariff trade barriers; export controls; dual-use goods
- Asset freezes
- Directions to cease business
- Anti-terrorism and non-proliferation
UN Sanctions
- The UN’s role in and approach to sanctions
- Member states and the application of UN sanctions
- UN Sanctioned countries
US Sanctions
- The Office of Foreign Assets Control
- Scope and applicability of US sanctions
- SDNs
- Sectoral sanctions: sanctions arising under the Russia/Ukraine crisis
- Countries under US sanctions and in what way
- Other: Magnitsky, Blood diamonds, non-proliferation, transnational criminal organisations.
- OFAC licences
Session 2
EU/UK Sanctions
- EU and UK sanctions post-Brexit – coordination and divergence
- Scope and who needs to comply
- Types of EU/UK sanctions
- Sectoral sanctions: sanctions arising under the Russia/Ukraine crisis
- UK specific: asset freezes, restrictions, directions to case business
- Proscriptions under the Terrorism Act 2000
- Designated persons
- Chemical weapons
- Meaning of ownership etc
- Penalties
Managing Sanctions Risk
- The business-wide sanctions risk assessment
- Identifying sanctions nexi and assessing and mitigating risks
- How to respond to sanctions challenges in a dynamic environment
- Screening and media searches
- Organisational red flags
- Third party red flags
- Clients and associated parties
- ID&V and beneficial ownership
- Sign off
Ongoing Monitoring
- Periodic reviews
- Trigger reviews: Types, analysis, who does what
- Internal reporting: when and to whom.
Delivery
Have the flexibility to deliver your In-House training in-person by one of our trainers at your premises, or virtually via Zoom, Teams or Webex.
Find out more about your Virtual or In-Person training experience below.
Virtual Delivery
Our virtual training courses are designed to be every bit as engaging as our in-person courses. To achieve this, our trainers use market-leading technology and a range of training techniques to ensure high levels of interaction with participants. Courses include the use of:
- Virtual ‘break-out’ rooms: participants are divided into virtual rooms to facilitate small group discussion.
- Polling: multiple-choice questions, answered anonymously, allow the trainer to assess knowledge and understanding across the group.
- Case studies: true to life case studies and scenarios are used to highlight the practical application of theoretical knowledge.
- Messaging: participants can submit questions and comments, either to the whole group or privately to the trainer.
Additional Benefits:
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Recording: public course participants have the option to access a recording of the course for one month after the course. In-House clients also have the option to record their training for an additional fee.
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On-going Q&A: public course participants can access an ongoing Q&A facility allowing them to ask questions relating to the course.
In-Person Delivery
Our in-person training is delivered face to face at your offices, and includes:
- ‘In-the-moment’ questions & discussions: questions through conversations allow the trainer to assess knowledge and understanding across the group.
- Case studies: true to life case studies and scenarios are used to explore practical application of theoretical knowledge.
- Q&A: participants can ask questions during training, either to the whole group or privately to the trainer.