Onsite Courses – Page 3 – The Risk Management Academy

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	SANCTIONS COMPLIANCE MASTERCLASS PROGRAM OUTLINE MODULE 1: HOW ARE SANCTIONS CREATED AND ENFORCED? Overview of Sanctions Compliance Types of Sanctions Who imposes sanctions? Regulatory Bodies and Authorities Sanctions Compliance Regulations 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 UN sanctions regime (Case example) MODULE 2: SANCTIONS TYPES, TARGETS, AND EXCEPTIONS What are the 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) MODULE 3: INTERNATIONAL CONSIDERATIONS IN SANCTIONS COMPLIANCE Understanding Jurisdictional Issues What is the jurisdictional reach of sanctions and who is subject to them? US primary vs secondary sanctions Who needs to comply with sanctions? Risks of sector-specific sanctions--- Risk of correspondent banking sanctions Sanctions risk for digital currencies Corporate supply chain sanctions Sanctions for maritime, logistics, and freight forwarders Goods and technologies of US origin Sanctions in the IT sector Sanctions on high-value and luxury goods Effective humanitarian license application Humanitarian aid distribution in authorized jurisdictions MODULE 4: SANCTIONS VIOLATIONS How do sanctions violations occur? Unintentional sanctions violations Sanctions evasion techniques: Payments Sanctions evasion techniques: Trade-based (Case example) Lessons from enforcement What are the consequences for not following sanctions Consequences: Regulatory, financial, reputational; Regulatory, financial, reputational (Case example) MODULE 5: 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 PLUS (Case example) MODULE 6: IDENTIFYING AND MANAGING SANCTIONS RISK Principles for an effective SRA Categories of customer risk: Customer, jurisdiction, product, channel Sector-specific sanctions risks Correspondent banking sanctions risk Digital currencies sanctions risk Corporate supply chain sanctions risk plus (Case example) Maritime, logistics, and freight forwarders sanctions risk Technology sector sanctions risk High-value and luxury goods sanctions risk MODULE 7: SANCTIONS DUE DILIGENCE How to 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) MODULE 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) MODULE 9: ADVANCED TOPICS IN SANCTIONS COMPLIANCE Sanctions and Emerging Technologies Blockchain and Distributed Ledger Technology (DLT) Artificial Intelligence (AI) and Machine Learning Cryptocurrency and Digital Assets 3D Printing and Advanced Manufacturing Sanctions Evasion and Enforcement Methods of Sanction Evasion Smuggling and Illicit Trade Front Companies and Shell Entities Cryptocurrency and Peer-to-Peer Transactions Regulatory Enforcement and Penalties The Huawei Case (2020) The Zhenli Ye Gon Case (2019) WHO CAN BENEFIT FROM THE PROGRAM? Sanctions compliance team Sanctions screening team Economic/Financial sanctions team Embargoes/Trade sanctions team Global trade, import/export team AML/CTF/CPF team Compliance technology team Legal counsel team Regulatory compliance team Risk management team Regulatory Compliance Compliance Analysts Compliance Managers KYC Analysts / Know Your Client Analysts KYC Managers AML/TF(Anti Money Laundering and Terrorist Financing) Analysts AML Managers Compliance Specialists Screening Analysts Customer Screening Analysts Transaction Screening Analysts Adverse Media Screening Analysts Corporate KYC/AML Analysts Onboarding Analysts Anyone in the financial compliance sector (private companies, regulated or non-regulated companies, banking, real estate, lawyers, or public sector employees). Compliance officers and risk management professionals Legal advisors and corporate counsel Banking and financial services professionals Trade and export control specialists Senior managers responsible for regulatory compliance PROGRAM DURATION: 3 DAYS	Quantity 1
	Security Risk Management	Quantity 1

SANCTIONS COMPLIANCE MASTERCLASS

PROGRAM OUTLINE MODULE 1: HOW ARE SANCTIONS CREATED AND ENFORCED?

Overview of Sanctions Compliance
Types of Sanctions
Who imposes sanctions? Regulatory Bodies and Authorities
Sanctions Compliance Regulations
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
UN sanctions regime (Case example)

MODULE 2: SANCTIONS TYPES, TARGETS, AND EXCEPTIONS

What are the 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)

MODULE 3: INTERNATIONAL CONSIDERATIONS IN SANCTIONS COMPLIANCE

Understanding Jurisdictional Issues
What is the jurisdictional reach of sanctions and who is subject to them?
US primary vs secondary sanctions
Who needs to comply with sanctions?
Risks of sector-specific sanctions---
Risk of correspondent banking sanctions
Sanctions risk for digital currencies
Corporate supply chain sanctions
Sanctions for maritime, logistics, and freight forwarders
Goods and technologies of US origin
Sanctions in the IT sector
Sanctions on high-value and luxury goods
Effective humanitarian license application
Humanitarian aid distribution in authorized jurisdictions

MODULE 4: SANCTIONS VIOLATIONS

How do sanctions violations occur?
Unintentional sanctions violations
Sanctions evasion techniques: Payments
Sanctions evasion techniques: Trade-based (Case example)
Lessons from enforcement
What are the consequences for not following sanctions
Consequences: Regulatory, financial, reputational; Regulatory, financial, reputational (Case example)

MODULE 5: 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 PLUS (Case example)

MODULE 6: IDENTIFYING AND MANAGING SANCTIONS RISK

Principles for an effective SRA
Categories of customer risk: Customer, jurisdiction, product, channel
Sector-specific sanctions risks
Correspondent banking sanctions risk
Digital currencies sanctions risk
Corporate supply chain sanctions risk plus (Case example)
Maritime, logistics, and freight forwarders sanctions risk
Technology sector sanctions risk
High-value and luxury goods sanctions risk

MODULE 7: SANCTIONS DUE DILIGENCE

How to 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)

MODULE 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)

MODULE 9: ADVANCED TOPICS IN SANCTIONS COMPLIANCE

Sanctions and Emerging Technologies
Blockchain and Distributed Ledger Technology (DLT)
Artificial Intelligence (AI) and Machine Learning
Cryptocurrency and Digital Assets
3D Printing and Advanced Manufacturing
Sanctions Evasion and Enforcement
Methods of Sanction Evasion
Smuggling and Illicit Trade
Front Companies and Shell Entities
Cryptocurrency and Peer-to-Peer Transactions
Regulatory Enforcement and Penalties
The Huawei Case (2020)
The Zhenli Ye Gon Case (2019)

WHO CAN BENEFIT FROM THE PROGRAM?

Sanctions compliance team
Sanctions screening team
Economic/Financial sanctions team
Embargoes/Trade sanctions team
Global trade, import/export team
AML/CTF/CPF team
Compliance technology team
Legal counsel team
Regulatory compliance team
Risk management team
Regulatory Compliance
Compliance Analysts
Compliance Managers
KYC Analysts / Know Your Client Analysts
KYC Managers
AML/TF(Anti Money Laundering and Terrorist Financing) Analysts
AML Managers
Compliance Specialists
Screening Analysts
Customer Screening Analysts
Transaction Screening Analysts
Adverse Media Screening Analysts
Corporate KYC/AML Analysts
Onboarding Analysts
Anyone in the financial compliance sector (private companies, regulated or non-regulated companies, banking, real estate, lawyers, or public sector employees).
Compliance officers and risk management professionals
Legal advisors and corporate counsel
Banking and financial services professionals
Trade and export control specialists
Senior managers responsible for regulatory compliance

PROGRAM DURATION: 3 DAYS