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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 course

pdf Download:   Course Outline

Session 1: 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
Advanced Sanctions Training 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 Act
  • 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-à-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 Training

  • 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 Sanctions Training)

  • OFAC Management Framework
  • Sanctions Compliance Programme – key points
  • Root causes of OFAC SCP breakdowns
Final Sanctions Training Case Study: Westpac’s Epic Fail

Our securities compliance course instructor is a specialist in investment banking governance, audit, risk, and compliance, bringing extensive international experience to his work. He holds an MBA from Bayes Business School in London and is a Chartered Certified Accountant. He began his career with Price Waterhouse in Kingston, Jamaica, before relocating to London in the wake of the 1986 financial “Big Bang.” Over the years, he has worked with several major financial institutions, including Manufacturers Hanover Trust, Continental Bank, CIBC, and ABN AMRO.

Throughout his career, he has held roles spanning internal audit, product control, risk management, and SOX compliance. His work across major global financial centres has given him deep expertise in regulation, governance, and internal controls across the full lifecycle of investment banking and capital markets products. His experience covers areas such as credit trading and derivatives, asset securitisation and structured finance, foreign exchange and FX options, interest rate derivatives, as well as commodities and treasury operations. In addition, he has taken on leadership responsibilities, playing a key role in developing and implementing strategic initiatives within global banking and markets, alongside delivering large-scale training and cultural change programmes across more than 50 countries.

In his current capacity, he delivers financial crime compliance programmes for leading global banks, including HSBC, Société Générale, SMBC, RBS, Lloyds, Nordea, and Handelsbanken. His training focuses on key areas such as anti-money laundering, sanctions compliance, tax evasion prevention, terrorist financing prevention, and anti-bribery and corruption measures, along with their associated governance frameworks. His programmes are designed for both frontline staff and senior management, reaching audiences across private, corporate, and retail banking sectors in the UK, Europe, Asia, the Middle East, Africa, and the Americas.

He has also served as a Master Trainer on HSBC’s global financial crime training programme and has developed specialised workshops on AML and sanctions with a focus on financial markets, securities, and investment products. His broader experience includes delivering train-the-trainer courses, presenting to US regulators, and providing instruction on audit, conduct risk, operational risk, treasury, Basel III, liquidity and capital management, and ICAAP. Additionally, as an Associate of RSM, he has conducted financial crime and regulatory compliance reviews for institutional clients and is the author of three books, including Clearing The Bull: The Financial Crisis And Why Banks Need A Human Transformation (2012).

Redcliffe Training's Advanced 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 in 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 you must address within financial institutions.
  • The major challenges presented by sanction evasion techniques.
  • Best practices in deterring and detecting sanctions risk violations.
  • Greater awareness of the roles and responsibilities of managing sanctions risks.

Advanced sanctions training is suitable for staff in entities with sanctions risk exposures, including:
  • Banks, asset 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

Redcliffe Training's sanctions training courses ensure you gain a comprehensive understanding of sanctions risks across both financial and non-financial institutions.

This course 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. This includes those imposed by authorities such as the United Nations, European Union, and the 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. Financial sanctions 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.

This course is available in virtual classrooms or can be delivered in-house.

  • 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 the course being 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.
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