Sanctions Compliance and Screening

Course overview

Course outline

1. 1Day 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
2. 2Day 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
3. 3Day 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
4. 4Day 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
5. 5Day 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