Managing Sanctions (CPD)

Wednesday 17th October 2018 09:00 – 12:30

Venue: Offices of Winckworth Sherwood, London

Minerva House, 5 Montague Close, London, SE1 9BB

“Firm A’s automated interdiction filter appropriately flagged Cire’s account five times between July 30, 2009 and November 16, 2009 for potential matches to the SDN list, and on each occasion, separate Risk Operations Agents dismissed the alerts without requesting additional information to clear the potential SDN name matches.  On February 14, 2013, Cire’s account (was flagged) for a sixth time and a Risk Operations Agent followed Firm A’s procedures for handling an SDN name match by creating a “case” for the match, restricting Cire’s account, and requesting additional information from the customer.  Upon receiving the requested information, which included a copy of Cire’s passport showing a date of birth and place of birth that were identical to those of the SDN, the Risk Operations Agent dismissed the match due to an apparent misunderstanding of why the interdiction filter had flagged Cire’s account for review. On the seventh occasion the account was blocked and reported to OFAC.  The total base penalty for this set of apparent violations was $17,000,000.”

Learning from history is critical to inform future conduct. Taking lessons from this true case study, and others more recently, join us on 17th October 2018 at the London offices of Winckworth Sherwood to learn more about how to manage the complex and important subject of international sanctions and the requirements of an effective framework of systems and controls that firms must have in place to avoid breaching international sanctions.

This course was developed and is run by The Great Chatwell Academy of Learning and brought to you in partnership with MLROs.com

 

About the Course

Sanctions can be used to support a wide range of outcomes including to suppress the financing and supply of terrorism; protect human rights; block trade as part of economic constraints; disrupt the development of weapons of mass disruption including nuclear proliferation; and are used to designate natural persons and legal entities that may be criminal or are supporting activity that is considered by the body to be unacceptable.

In this course delegates will trace the evolution of sanctions to the modern day, looking at key international sanctions laws and regulations including those of the UN, USA, EU and UK. This will include the very latest developments concerning North Korea, Iran and Russia.

The course is designed to guide and inform delegates on critical definitions and the scope of sanctions, and to provide greater confidence in managing and implementing effective strategies to manage trade, economic and financial sanctions.

Critically, we will look at some of the steps sanctions evaders can take to avoid sanction controls, including those products, services, regions and operations that are more closely linked to sanctions risk.

Using real-life case studies, exercises and learning from the peer group, delegates will be encouraged to develop a practical understanding on how to manage sanctions risks and how to meet the challenge set by criminals, whilst meeting legal and regulatory compliance responsibilities.

The Course will be suitable for:

  • Existing sanctions monitoring operations staff who wish to revise their skills and knowledge, and to learn more about new and emerging best practices
  • All risk professionals including financial crime compliance (FCC) and anti-money laundering practitioners
  • MLRO, Deputy MLRO and nominated officers
  • Audit, Risk, FCC and compliance professionals supervising Commercial, Commodity and Trade Finance functions of regulated institutions
  • Operational and processing professionals handling Trade Finance and International Payments (including SWIFT transactions) and relationships

Course Overview and Expected Learning Outcomes

Delegates will learn more about the background and growth in the use of sanctions as a form of international foreign policy, and of the current sanctions laws and regulations that must be complied with from the UN, USA, EU and UK governments, and how to comply with these licensing regimes.

A key expected learning outcome will be that delegates will develop a deeper understanding of some of the key typologies used by sanctions evaders to avoid detection, including the use of formal and informal front persons, undisclosed beneficial ownership, complex business structures and layering.

Of course, we will also look at some of the very latest best practises being used to counter the activity of sanctions evaders, using technology such as fuzzy logic, and red flag indictors to guide staff to identify and uncover suspected criminal conduct.

Keywords and Topic Areas

  • Sanctions authorities; OFAC, UK HMT, HKMA, UN Security Council, EU
  • Specially Designated Nationals
  • Fines and history of non-compliance case studies
  • Evasion and circumvention
  • Wire Stripping and U-Turn
  • Freezing
  • Governance Structures
  • Dual Use goods and Proliferation
  • SWIFT payments and transaction monitoring
  • CDD vs Screening
  • Direct and indirect exposures
  • Trading with the Enemy Act, US Patriot Act, State Sponsor of Terror
  • Embargos
  • Typologies and jurisdiction risk

At the end of the course delegates will be provided with a certificate attesting to their attendance and participation.