Advanced Sanctions Risks

A thorough analysis of the critical topics in sanctions risk management

A chessboard with the pieces arranged in a strategic position

A one day sanctions risk training

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Download: Course Outline

Session 1: Sanctions Risk Training Introduction

The Global Sanctions Framework
Applying Sanctions

Session 2: US Sanctions on Russia

Countering American Adversaries Through Sanctions Act (CAATSA) SSIs:
- Financial institutions
- Energy companies
- Defence and Intelligence Agencies
- Overseas ownership by energy companies
Facilitation and secondary sanctions
Investment in state-owned enterprises
Restrictions on Crimea
Crimea sanctions:
- Technology and the Defence Sector
- Russian sovereign debt
Russian Harmful Foreign Activities Sanctions:
- Major Russian Banks
- Oligarchs and 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

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 and Restrictions:
- Individual Bans & Asset Freezes
- EU Capital & Financial Markets
- Financial Institutions
- Defence & Dual Use Goods
- Major Industry Sectors
- Investments
- Investment Services & Products
- State-Owned Enterprises
- Public Investments
- Nord Stream 2

Brokering, Financing or Guaranteeing Restrictions

Sanctions Risk Course 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 and restrictions:
- Banking and financial markets
- Major Russian Banks
- Major Russian Companies
- Public Investments
- State-Owned Enterprises
- Dual-use goods and technology
- Exports and import bans
Other countries sanctions on Russia

Session 5: Sanctions on Belarus

Travel Bans and asset freezes on individuals
Prohibitions and restrictions:
- Imports and exports
- Defence
- Major sectors of the economy
- Investments
- State-owned entities
- SWIFT
- Banking and financial markets

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

Iran:
- Non-proliferation
- Defence
- Travel bans and asset freezes
- Energy and energy investments
- Collapse of the JCPOA
- Major sectors of the economy
- Iranian Security Services
North Korea:
- CAATSA North Korea
- UNSC Sanctions
- Non-Proliferation
- Defence and military
Syria:
- Energy and energy investments
- Travel bans and asset freezes
Myanmar:
- Restrictions and prohibitions
- Regime focus
- Implications for business

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

Sanctions risk online training examines trade finance and 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 and indirect sanctions 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 and ZTE
Siemens in Russia
Russian Sanctions Evasion
Iran and Turkey
Gold and cryptocurrencies
Non-Bank Financial Institutions (NBFIs)
Integration of money laundering and 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

Session 12: Sanctions Screening

Who do we screen?
When do we screen?
Payment and transaction screening
Sanctions Data Framework
Patriot Act
Payment transparency
Fines and penalties
Sanctions narrative and the 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

Sanctions risk course final case study: Westpac’s Epic Fail

Sanctions risk training at Redcliffe is delivered by an investment banking governance, audit, risk and compliance specialist with 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 before arriving in London just after the 1986 "Big Bang". He has worked for several 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.

This sanctions risk course expert 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.

He currently delivers financial crime courses for major banks (HSBC, Soc Gen, SMBC, RBS, Lloyds, Nordea and Handelsbanken) covering AML, Sanctions, Tax Evasion, Terrorist Financing Bribery & Corruption, as well as their related governance aspects. This delivery encompasses frontline staff and senior managers across global markets, private, corporate and retail banking in the UK, Europe, Asia, the Middle East, Africa, the US and the Americas. He was a Master Trainer on HSBC’s global financial crime training programme.

Based on his considerable experience in the financial markets, he has developed specialist AML and Sanctions workshops in financial market products, securities and investments. He has also run train-the-trainer (TTT) courses and delivered presentations for US regulators. In addition, he has delivered training programmes in Audit, Conduct Risk, Operational Risk, Treasury, Basel III, Liquidity Management, Capital Management and the Internal Capital Adequacy Assessment Process (ICAAP).

He is also the author of three books including Clearing The Bull: The Financial Crisis And Why Banks Need A Human Transformation (2012 iUniverse).

Redcliffe’s sanctions risk course will assist you in developing:

An understanding of the major US, EU and UK sanctions regimes and how they impact financial institutions. Especially those concerning Russia, Iran, North Korea, Syria, Cuba, Belarus and China.
A deeper understanding of the nature of sanctions regimes and the nature of sanctions risk exposures.
A deeper understanding of how sanctions risk exposures arise, how they permeate business activities in financial institutions and their business relationships.
Awareness of key sanctions risk management topics and issues that must be addressed within financial institutions.
The major challenges presented by sanction evasion techniques.
Best practices in deterring and detecting sanctions risk violations.
Sanctions risk training will ensure you gain a greater awareness of the roles and responsibilities of managing sanctions risks.

An overview and analysis of major Western sanctions regimes.

Insight into how sanctions risk exposures arise and how they might be properly assessed.
Effective insights, approaches and best practices in the management and mitigation of sanctions risk exposures.
Numerous case studies and exercises are drawn directly from specific events and institutional failures. As such, this sanctions risk course will be highly interactive.
Developed and delivered by a professional trainer with extensive experience in banking and the financial markets, as well as training in financial crime in both wholesale and retail markets.

This advanced sanctions risk 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 who make 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 sanctions risk online training course ensures you gain a comprehensive understanding of sanctions risks across both financial and non-financial institutions. It provides an in-depth exploration of critical topics, such as the identification and assessment of sanctions risks, the intricacies of the evolving regulatory landscape, and the vital role that robust compliance frameworks play in mitigating these risks.

Participants will gain a deep understanding of how to navigate the nuances of international sanctions regimes, including those imposed by authorities such as the United Nations, European Union, and U.S. government.

Tailored for professionals at all levels, this comprehensive course blends in-depth theoretical knowledge with practical insights, enabling delegates to understand the complexities of sanctions and apply best practices in real-world scenarios.

Sanctions risk training provides significant value to sanctions specialists, financial crime professionals, risk managers, and executives responsible for overseeing their organisation’s sanctions risk exposures, helping them strengthen compliance frameworks and mitigate potential risks.

The presentation was lively and there was good interaction among the 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.
The course has provided me with a deeper knowledge of sanctions and specific behaviours to be aware of when onboarding new customers.
The course was more than what I had expected. Despite that the course was held for several hours it was presented in a very good and interesting way which kept me focused throughout the presentation.
I think the highlight of the course was when the different types of risky behaviours presented throughout the course were related to real-life scenarios.
It will be useful in my daily work when we support the business in relation to sanction topics, primarily related to payments, KYC, and trade finance transactions.
Although I could not contribute much to the exercises, it was useful to listen to those who work daily with Sanctions. Hear their reasoning and then when we all gathered for a briefing, more fell into place and you get a better picture. Even if it is within a large area.
Everything was perfect. The content of the training is broad and covers several topics related to sanctions risk assessment.
A good trainer who asked questions and gave relevant examples.
The trainer was incredibly well-versed in the historical context of the sanctions, which enabled a better understanding of how and why they are enforced and structured.