Sanctions Compliance and Screening

Introduction

Economic and trade sanctions have become one of the most dynamic and high-risk areas of compliance. Sanctions regimes change quickly, apply across borders and can affect payments, trade, shipping, investments and ordinary commercial relationships. Breaches can result in heavy penalties, loss of banking relationships and serious reputational harm.

This Sanctions Compliance and Screening training course explains how sanctions work and how organisations can build an effective, risk-based sanctions compliance programme. Participants learn about the main types of sanctions, ownership and control rules, screening of customers, counterparties and transactions, alert investigation, and the handling of potential matches and breaches.

The course also covers sanctions evasion techniques, trade and shipping risks, governance, testing and the practical tuning of screening systems.

Course Objectives

By the end of this training course, participants will be able to:

• Explain the purpose and main types of economic and trade sanctions
• Understand the key international and national sanctions regimes in overview
• Apply ownership and control principles to counterparties
• Design a risk-based sanctions compliance programme
• Screen customers, counterparties and transactions effectively
• Investigate and resolve screening alerts consistently
• Recognise sanctions evasion red flags in trade and payments
• Respond appropriately to potential breaches and reporting duties

Target Audience

This training course is suitable for a wide range of professionals, including:

• Compliance and sanctions officers
• Anti-money laundering professionals
• Trade finance and payments operations staff
• Export control and logistics professionals
• Legal and risk professionals
• Internal auditors reviewing compliance programmes
• Screening analysts and investigators

Training Methodology

The course uses real-world style case studies, screening alerts and transaction scenarios. Participants practise alert adjudication, ownership analysis and red flag identification, and design elements of a sanctions programme. Discussions examine recent enforcement themes and how organisations have improved their controls.

Target Competencies

• Sanctions regime awareness
• Ownership and control analysis
• Screening programme design
• Alert investigation
• Evasion red flag recognition
• Breach response

Day One: Understanding Sanctions

• The purpose of sanctions and how they are imposed
• Asset freezes, sectoral sanctions, trade and travel restrictions
• Overview of major international and national sanctions regimes
• Extraterritorial reach and secondary sanctions
• Licences, exemptions and general authorisations
• Recent trends and lessons from enforcement actions
• Quiz: identifying sanctions exposure in business scenarios

Day Two: Building a Sanctions Compliance Programme

• Management commitment, policy and governance
• Conducting a sanctions risk assessment
• Customer and counterparty risk factors
• Product, service, channel and geographic risks
• Roles, training and escalation arrangements
• Record keeping and documentation requirements
• Workshop: drafting a sanctions risk assessment

Day Three: Screening Customers and Counterparties

• Screening lists, data sources and update frequency
• Name matching, fuzzy logic and transliteration challenges
• Ownership and control rules and aggregated holdings
• Onboarding and periodic rescreening
• Tuning screening systems to reduce false positives
• Testing and validating screening effectiveness
• Exercise: analysing ownership structures for sanctions risk

Day Four: Transaction Screening and Alert Investigation

• Payment and trade transaction screening processes
• Investigating alerts and distinguishing true from false matches
• Documenting decisions and maintaining an audit trail
• Escalating and blocking or rejecting transactions
• Shipping, vessel and port-related sanctions risks
• Dual-use goods and export control interactions
• Exercise: adjudicating a set of screening alerts

Day Five: Evasion, Breaches and Programme Assurance

• Common sanctions evasion techniques and red flags
• Use of front companies, intermediaries and transshipment
• Responding to a potential sanctions breach
• Voluntary disclosure and regulatory reporting considerations
• Independent testing and internal audit of sanctions controls
• Keeping the programme current as regimes change
• Personal action plan for sanctions compliance