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)

There are no prerequisites to this course.

Pass a 20-question final assessment to receive your certificate.

Following your booking, a confirmation message will be sent to all participants, ensuring you're well-informed of your successful enrollment. Calendar placeholders will also be dispatched to assist you in scheduling your commitments around the course. Rest assured, all course materials and access to necessary labs or platforms will be provided no later than one week before the course begins, allowing you ample time to prepare and engage fully with the learning experience ahead.

Our comprehensive training package includes all the necessary materials and resources to facilitate a full learning experience. Enrollees will be provided with detailed course content, encompassing a wide array of topics to ensure a thorough understanding of the subject matter. Additionally, participants will receive a certificate of completion to recognize their dedication and hard work. It's important to note that while the course fee covers all training materials and experiences, the examination fee for certification is not included but can be purchased separately.

Questions About This Course?