2 Part Course  | 
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Advanced Sanctions Risks

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

A chessboard with the pieces arranged in a strategic position

A sanctions risk training programme delivered online over 2 half-day sessions or in a single-day classroom session.

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

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 and 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 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

  • 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 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 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 before arriving in London just after the Big Bang in 1986. 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 trainer 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 courses in financial market products, securities and investments. He has also run train-the-trainer (TTT) courses and delivered presentations in front of 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).

To 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 some of the 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 training will ensure you gain a greater awareness of the roles and responsibilities of managing sanctions risks.

Sanctions training is designed to provide:
  • 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.
  • The course is 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 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

This sanctions course is designed to improve your 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.

Sanctions risk training 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 sanctions risk 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
  • The course has provided me a deeper knowledge about sanctions and specific behaviors to be aware of when onboarding new customers.
  • The course was more then 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 highlight of the course was when the different types of risky behaviors presented throughout the course was 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 in 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.
  • Good trainer that asked questions and gave relevant examples.
Number of places:
Part 1

£ 695.00

Number of places:
Part 2

£ 695.00

Discounts available:
Virtual Class

  • 2 places at 30% less
  • 3 places at 40% less
  • 4 places at 50% less
  • 5 places at 55% less
  • 6+ places at 60% less
  • Select the number of course places and dates to automatically calculate the discount
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