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Advanced Sanctions Risks

2 Part Course  |  Learn from a thorough analysis of important topics in sanctions risk management

Advanced Sanctions Risks Training Course

A one-day course presented in two half-day live webinars

The course is suitable for staff in entities with sanctions risk exposures, including

  • Banks, assets managers, hedge funds, brokers and other financial institutions with sanctions
    • Compliance, Audit, Legal and other Risk Professionals
    • Frontline Relationship Managers, Advisors, Salespersons and Traders making routine decisions on financing and investment on behalf of their customers and their firms
    • Customer Due Diligence, Transaction Processing, Operations and Administrators
  • International Law Firms, Accountants, Real Estate Agents, Trust & Corporate Services
  • Commodity Trading Firms
  • Oil companies and Multinationals

The course is designed to provide

  • A very good overview and analysis of major western sanctions regimes
  • An examination of sanctions risk exposures arisen and how they might be properly assessed.
  • Effective insights and approaches to best practices in the management and mitigation of sanctions risks exposures
  • Numerous case studies and exercises drawn directly from specific events, institutional failures, and as such will be highly interactive

The course is developed and delivered by a professional trainer with extensive experience in banking and the financial markets, as well as training financial crime in both wholesale and retail markets

To assist participants in developing

  • Their understanding of the major US, EU & UK sanctions regimes and how they impact financial institutions, especially those in respect of Russia, Iran, North Korea, Syria, Cuba, Belarus & China
  • A deeper understanding of the nature of sanctions regimes and the nature of sanctions risks exposures
  • A deeper understanding of the way in which sanctions risk exposures arise and permeate business activities in financial institutions and their business relationships
  • Their knowledge and awareness of some of the key sanctions risk management topics and issues that must be addressed within financial institutions
  • Their understanding of the major challenges presented by sanction evasion techniques
  • Their knowledge and awareness of best practices in deterring and detecting sanctions violations risk
  • A greater awareness of their roles and responsibilities in respect of the management of sanctions risks

Part One

Session 1: Introduction

  • The Global Sanctions Framework
  • Applying Sanctions

Session 2: US Sanctions on Russia

Sanctions Pre Ukraine-Invasion

  • Countering American Adversaries Through Sanctions Act (CAATSA) SSIs
    • Financial Institutions
    • Energy Companies
    • Defence & Intelligence Agencies
    • Overseas Ownership by Energy Companies
  • Facilitation & Secondary Sanctions
  • Investment in State-Owned Enterprises
  • Restrictions on Crimea
  • Crimea Sanctions
    • Technology & Defence Sector
    • Russian Sovereign Debt
  • Russian Harmful Foreign Activities Sanctions
    • Major Russian Banks
    • Oligarchs & Proxies
    • Imports & Exports
    • Investments
    • Definition of Investment
    • Sovereign Debt
    • Energy
    • Ministry of Finance, Sovereign Wealth Fund & Central Bank
    • Correspondent & Payable Through Accounts (PTAs)
  • Prohibitions on Services 

Exercise: Company A
Case Study: Sibneft Privatisation
Case Study: The Russian Laundromat

Session 3: EU Sanctions on Russia

Pre Ukraine-Invasion

  • Prohibitions & Restrictions
    • Finance
    • Defence
    • Dual-Use Goods
    • Energy
    • Economic Cooperation
  • Asset Freezes and Travel Bans on Individuals
  • Crimea Restrictions
    • Business
    • Investment
  • SWIFT Ban on Major Banks
  • Prohibitions & Restrictions
    • Individual Bans & Asset Freezes
    • EU Capital & Financial Markets
    • Financial Institutions
    • Defense & Dual Use Goods
    • Major Industry Sectors
    • Investments
    • Investment Services & Products
    • State-Owned Enterprises
    • Public Investments
    • Nord Stream 2
  • Brokering, Financing or Guaranteeing Restrictions

Exercise: Sanctions Product Evaluation

Session 4: UK Sanctions on Russia

Pre Ukraine-Invasion

  • The Russia (Sanctions) (EU Exit) Regulations 2019
  • Differences with the EU Regime
  • Asset Freezes & Travel Banks on Individuals
  • Restrictions on Crimea
  • Prohibitions & Restrictions
    • Banking & Financial Markets
    • Major Russian Banks
    • Major Russian Companies
    • Public Investments
    • State-Owned Enterprises
    • Dual-Use Goods & technology
    • Exports & Import Bans
  • Other Country Sanctions on Russia

 Session 5: Sanctions on Belarus

  • Travel Bans and Asset Freezes on Individuals
  • Prohibitions & Restrictions
    • Imports & Exports
    • Defence
    • Major Sectors of the Economy
    • Investments
    • State-Owned Entities
    • SWIFT
    • Banking & Financial Sanctions Markets

 Session 6: Sanctions on Iran, North Korea, Syria & Myanmar

  • Iran
    • Non-Proliferation
    • Defence
    • Travel Bans & Asset Freezes
    • Energy & Energy Investments
    • Collapse of the JCPOA
    • Major Sectors of the Economy
    • Iranian Security Services
  • North Korea
    • CAATSA Sanctions North Korea
    • UNSC Sanctions
    • Non-Proliferation
    • Defense & Military
  • Syria
    • Energy & Energy Investments
    • Travel Bans & Asset Freezes
  • Myanmar Restrictions & Prohibitions
    • Regime Focus

Implications for Business

Part Two

Session 7: Sanctions on China, Venezuela & Cuba

  • China
    • CMICs
    • SDN vs Non-SDN
    • Subsidiaries
    • Investment & Advisory Services
    • Future Designations
  • Venezuela Sanctions Targets
    • The Regime
    • PdVSA
  • US Embargo on Cuba

 Session 8: Beyond Sanctions – Trade & Human Rights

  • Trade Finance & Sanctions Risks
  • US Export Administration Regulations (EAR)
  • Magnitsky Act & Global Magnitsky Acts
  • EU & UK Human Rights Regulations

Session 9: Assessing Sanctions Risk Exposures

  • The Risk Based Approach
  • Who is Subject to US Sanctions?
  • Direct & Indirect Sanctions Checking Exposures
  • Assessing Sanctions Risk Exposures
  • Affiliate Risk Management

Case Study: Singapore Telecom
Case Study: The UNDP in North Korea
Case Study: Standard Chartered
Exercise: US Nexus
Exercise: Direct & Indirect Exposure

Session 10: Key Topics in Sanctions Evasion

  • Huawei & ZTE
  • Siemens in Russia
  • Russian Sanctions Evasion
  • Iran & Turkey
  • Gold & Cryptocurrencies
  • Non-Bank Financial Institutions (NBFIs)
  • Integration of Money Laundering & Sanctions Evasion Techniques
  • North Korea

Case Study: Turkey and Iran’s Gold Trades
Case Study: Russian / Gazprom Offshore Financing
Case Study: Cryptocurrency Expert in North Korea

Session 11: Sanctions CDD

  • The Sanctions CDD Framework
  • Is there a difference vis-a-vis regular CDD?
    • ID & V
    • KYC
    • ODD
    • EDD
  • Beneficial Ownership
  • Trigger Events

Case Study: 650 Fifth Avenue, New York
Case Study: Ongoing Due Diligence
Exercise: Hidden Ownership Sanctions Case Study

Session 12: Sanctions Screening

  • Who Do We Screen?
  • When Do We Screen?
  • Payment & Transaction Screening
  • Sanctions Data Framework
  • Patriot Act
  • Payment Transparency
  • Fines & Penalties
  • Sanctions Narrative, Customer Ecosystem
  • Importance of Frontline Staff

Case Study: BNP Paribas
Case Study: Putin & The Proxies

Session 13: Sanctions Risk Management

  • OFAC Management Framework
  • Sanctions Compliance Programme – Key Points
  • Root Causes of OFAC SCP Breakdowns

Case Study: Westpac’s Epic Fail

The trainer, MBA FCCA, is an investment banking governance, audit, risk and compliance specialist who has extensive international experience. He holds an MBA from CASS Business School, London and is a Chartered Certified Accountant.

He worked for Price Waterhouse in Kingston, Jamaica prior to arriving in London just after Big Bang in 1986 and subsequently worked for a number of major institutions including Manufacturers Hanover Trust, Continental Bank, CIBC and ABN AMRO. His roles have included internal audit, product control, risk management and SOX.

In addition to gaining experience in the major global financial centres the above roles covered all aspects of regulation, governance and internal controls over the origination, sales and trading of a broad range of investment banking and capital market products. These products include credit trading and credit derivatives; asset securitisation and structured finance; foreign exchange and foreign exchange options; interest rate derivatives; commodities and treasury.

He has also served as a business manager where he played a leading role in the development and implementation of major strategic initiatives within global banking and markets. This was followed by the delivery of a training and cultural change programme in alignment with that strategy, across 50 countries.

The trainer currently focuses on delivering financial crime courses for major banks (HSBC, Soc Gen, RBS, Lloyds, Nordea and Handelsbanken) covering AML, Sanctions, Tax Evasion, Terrorist Financing Bribery & Corruption, as well as their related governance aspects. This delivery encompassed frontline staff and senior managers across global, private, corporate and retail banking in the UK, Europe, Asia, Middle East, Africa, US and the Americas.

He has also run train the trainer (TTT) courses and presented in front of US regulators. In addition, he delivers training programmes in Audit, Operational Risk, Treasury, Basel III, Liquidity Management, Capital Management and the Internal Capital Adequacy Assessment Process (ICAAP).

He has delivered over 150 courses online via WebEx and Zoom.

The course is designed to improve participants’ awareness and knowledge of sanctions risks in financial and non-financial institutions. It focuses on some of the most significant control issues and how best to approach the development of a sanctions risk management framework. The course will be of significant benefit to sanctions specialists, financial crime specialists and other risk professionals, as well as executives and managers who have a responsibility for managing their organisation’s indirect sanctions risk assessment exposures.

  • Presentation was lively and there was good interaction with participants
  • The structure, cases and examples were all great
  • The instructor was able to explain the content and was clearly very knowledgeable in this field as he was able to answer questions succinctly and add additional depth to the topic. The explanations of the level of sanctions and how far reaching these were, along with the case studies
Number of places:
Part 1
Number of places:
Part 2

£695.00

Per participant per part

Discounts available:

Book multiple places on both parts in one order for the below discounts:

  • 2+ places at 40% less = £834.00
    per person
  • 4+ places at 50% less = £695.00
    per person
  • 6+ places at 60% less = £556.00
    per person
  • 9+ places at 70% less = £417.00
    per person
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