Course Summary
This foundation course will introduce you to the principles underpinning sanctions compliance, help you understand your own unique risk, and what controls should be applied.
What you’ll learn:
• How sanctions are created and enforced
• The different sanctions types, their targets and exceptions
• The jurisdictional reach of sanctions and to whom the concept applies
• How violations happen and how to prevent them
• What a robust sanctions compliance program looks like
• How to conduct sanctions due diligence
• What sanctions screening is and how it is applied
• Investigating and reporting sanctions breaches
Participants of this course may be early in their compliance career, learning about sanctions for the first time, professionals seeking a refresher course or those looking to progress to the flagship:
Certified Global Sanctions Specialist (CGSS).
1. Getting Started / Introduction
• DPRK Services case
• What would you do?
• Feedback
2. Sanctions origins and legal framework
What are sanctions and why do they exist?
• Sanctions
• History of sanctions
• Sanctions: National and international security
How are sanctions created and enforced?
• Who imposes sanctions?
• United Nations sanctions regime
• European Union sanctions regime
• United States sanctions framework
• United States sanctions regulatory agencies
• United Kingdom sanctions regime
• Unilateral sanctions
• Influential organizations
• CPF / CFT
• UN sanctions regime (Case example)
3. Sanctions types, targets, and exceptions
What are the types of sanctions?
• Types of sanctions and embargoes
• Financial and economic sanctions
• Asset freeze and making funds available
• Trade sanctions including arms embargoes
• Trade sanctions: Items subject to export control
• Comprehensive vs targeted sanctions
• Sectoral sanctions
Are there exceptions made for sanctions?
• Sanctions exceptions, exemptions, and licenses
• Grounds for sanctions licensing
• Effective application of humanitarian licenses
• Managing indirect sanctions exposure (Case example) 4. Jurisdictional reach of sanctions
What is the jurisdictional reach of sanctions and who is subject to them?
• US primary vs secondary sanctions
• Who needs to comply with sanctions?
• US-origin goods and technology
• Jurisdictional reach of US secondary sanctions
• US secondary sanctions and significant transactions
• US-origin goods and technology (Case example)
• Jurisdictional cross-border legal and regulatory conflicts
• Sanctions blocking regulations (Case example)
5. Sanctions violations
How do sanctions violations occur?
• Unintentional sanctions violations
• Sanctions evasion techniques: Payments
• Sanctions evasion techniques: Trade-based
• Sanctions evasion techniques: Trade-based maritime (Case example)
• Lessons from enforcement
What are the consequences for not following sanctions
• Consequences: Regulatory, financial, reputational
• Consequences: Regulatory, financial, reputational (Case example)
6. Sanctions compliance program
What aspects form a robust and effective SCP?
• Framework for a robust SCP
• Management commitment / culture of compliance
• Sanctions risk assessment • Internal controls
• Testing and audit
• Sanctions compliance training
• Staying current on sanctions
• Sanctions easing and lifting
• Sanctions easing and lifting (Case example)
Identifying and managing sanctions risk
• Principles for an effective SRA
• Categories of customer risk: Customer, jurisdiction, product, channel
• Sector-specific sanctions risks (Introduction)
• Correspondent banking sanctions risk
• Digital currencies sanctions risk
• Corporate supply chain sanctions risk
• Corporate supply chain sanctions risk (Case example)
• Maritime, logistics, and freight forwarders sanctions risk
• US-origin goods and technology (Reminder)
• Technology sector sanctions risk
• High-value and luxury goods sanctions risk
• Effective application of humanitarian licenses (Reminder)
• Humanitarian delivery in sanctioned jurisdictions
7. Sanctions due diligence
How do I conduct sanctions due diligence?
• Know your customer requirements
• Know your customer due diligence
• Enhanced due diligence for sanctions
• Due diligence investigations for sanctions (Case example) Understanding beneficial ownership
• Transparency, ownership, and control
• OFAC 50% rule
• EU and UK ownership and control
• Concealment of beneficial ownership
• KYC due diligence (Case example)
• OFAC 50% rule (Case example)
8. Sanctions screening, investigation, and incident management
What is sanctions screening and how does it work?
• Sanctions screening
• Types of sanctions screening
• Sanctions Screening: Amazon (Case example)
What do we do when the risk emerges?
• Dealing with a sanctions breach
• Self-reporting a potential breach of sanctions
• Incident management as part of an SCP
• Sanctions Compliance Foundations (Summary)
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