Advanced Sanctions - Securities & Investments

Session 1: Ownership & Customer Due Diligence

The challenge of determining ownership structures given the propensity for sanctioned individuals and entities to use family members and other proxies.

• The Ownership Challenge
• OFAC 50% Rule
• OFAC 33% Rule
• Enhanced Due Diligence on Beneficial Ownership
• Strategic Dilemma: Risk Appetite
• Exercise: Hidden Ownership

Session 2: US Sanctions on Russia I

• Countering American Adversaries Through Sanctions Act (CAATSA)
• Russian Sectoral Sanctions Identifications (SSIs)
  • Directives 1, 2, 3 & 4
  • CAATSA Definitions of Debt & Equity
  • Application of Secondary Sanctions
  • Facilitation & State Entities
  • CAATSA Definition of Investment
  • General Licence 1B: Derivatives
  • CAATSA Anti Avoidance & Facilitation Provisions
•  Case Study: Company A
• Case Study: The Russian Laundromat
• Case Study: Russian Offshore Financing
• Case Study: Sibneft Privatisation
• Exercise: Product Evaluation

Session 3: US Sanctions on Russia II

• Executive Order 14024
• Russian Harmful Foreign Activities Directive 1
  • Government & Major Sectors of the Russian Economy
  • Financing, Facilitating or Supporting
  • Deceptive & Structured Transactions: Digital & Physical Assets
  • Secondary Sanctions: Foreign Financial Institutions
  • Russian Bank Units and Subs Overseas
• Russian Harmful Foreign Activities Directive 2
  • Prohibitions on Correspondent & Payable Through Accounts
• Russian Harmful Foreign Activities Directive 3
  • New Debt & Equity Restrictions Major Russian Entities
• Russian Harmful Foreign Activities Directive 4
  • Restrictions on Russian Sovereign Debt
• Prohibitions on Occupied Ukraine
• Prohibitions of Executive Orders 14066, 14068, 14071
  • Energy, Investments, Luxury Goods and Services
• Facilitation, Oligarchs & Proxies
• Other Major Sanctions
• Case Study: Putin & the Proxies
• Exercise: GVA Capital

Session 4: EU Sanctions on Russia

• Russia Sanctions Overview
• EU Sectoral Sanctions
  • Major Industry
  • Financial Sector
  • Capital Markets & Financing
  • Investment Services
• EU Definitions
  • Financing
  • Investment Services
  • Transferable Securities
  • Derivatives
• EU Treatment of Derivatives
• Prohibitions
  • Trust & Corporate Services
  • Brokering & Financing
  • Circumvention
  • Annexed Territories
  • Professional Services
• Case Study: OFAC Settlement Wells Fargo
• Case Study: Mirror Trades

Session 5: UK Sanctions on Russia

• The Russia (Sanctions) (EU Exit) Regulations 2019
  • Transferable Securities
  • Derivatives
  • Loans & Credit
  • Occupied Territories
• EU Exit Amendments
  • Major Industries
  • Payment Processing
  • Correspondent Banking
  • Financial Services, Funds, Brokering
  • Trust & Corporate Services
  • Professional Services
• General UK Sanctions Measures
  • Derivatives
• Prohibitions on Central Bank, Wealth Fund, Ministry of Finance
  • Financial Services
  • Exchange, Reserve & Asset Management
• Exercise: Market & Currency Flows

Session 6: China & Venezuela

• US Sanctions On China: Executive Order 14032
  • Non SDN
  • Chinese Military Industrial Companies (CMICs)
  • Prohibition on Securities
  • Definitions & Treatment of Derivatives
  • Specific Names
  • Application of 50% Rule to Subsidiaries
  • Investment Advisory Services
• Venezuela Sanctions & Prohibitions
  • Government
  • PdVSA
  • Central Bank
  • Access to US Financial Markets
  • Other Financial Sanctions
• Case Study: Hunger Bonds
• Case Study: Interactive Brokers

Our securities compliance course instructor is an investment banking governance, audit, risk, and compliance specialist with extensive international experience. He holds an MBA from Bayes Business School (formerly Cass) in London and is a Chartered Certified Accountant.

After beginning his career with Price Waterhouse in Kingston, Jamaica, he moved to London following the Big Bang in 1986. He subsequently worked for several major financial institutions, including Manufacturers Hanover Trust, Continental Bank, CIBC, and ABN AMRO.

His roles have encompassed internal audit, product control, risk management, and SOX compliance. Working across major global financial centres, he has gained comprehensive experience in regulation and compliance, governance, and internal controls covering the full lifecycle of investment banking and capital market products, including:

• Credit trading and credit derivatives
• Asset securitisation and structured finance
• Foreign exchange and FX options
• Interest rate derivatives
• Commodities and treasury operations

Leadership and Strategic Experience

As a business manager, he played a leading role in developing and implementing major strategic initiatives within global banking and markets. He delivered training and cultural change programs aligned with these strategies across 50 countries.

Current Training Expertise

Today, our sanctions and securities compliance course specialist delivers financial crime compliance programs for major banks, including HSBC, Société Générale, SMBC, RBS, Lloyds, Nordea, and Handelsbanken. His training covers:

• Anti-Money Laundering (AML)
• Sanctions compliance
• Tax evasion prevention
• Terrorist financing prevention
• Bribery and corruption prevention
• Related governance aspects

His training reaches frontline staff and senior managers across global financial compliance, private banking, corporate banking, and retail banking in the UK, Europe, Asia, the Middle East, Africa, the US, and the Americas.

Specialised Programs

He served as a Master Trainer on HSBC's global financial crime training program and has developed specialist AML and sanctions workshops focused on financial market products, securities, and investments. He has also:

• Conducted train-the-trainer (TTT) courses
• Delivered presentations for US regulators
• Provided training in Audit, Conduct Risk, Operational Risk, Treasury, Basel III, Liquidity Management, Capital Management, and the Internal Capital Adequacy Assessment Process (ICAAP)

Additional Experience

As an Associate of RSM, he conducted several financial crime and regulatory compliance reviews for institutional clients. He is also the author of three books, including Clearing The Bull: The Financial Crisis And Why Banks Need A Human Transformation (2012, iUniverse).

• The course objectives are to analyse and develop a critical understanding of the impact of sanctions on securities, financing and investments within the context of capital markets and wholesale banking products and services.
• The course will focus on major sanctions regimes, where there are specific securities, finance and investment sanctions risks, including:
  • EU, US & UK Sanctions on Russia
  • China & Venezuela

The course is suitable for staff in:

• Banks, asset managers, hedge funds, brokers and other financial institutions including:
  • Compliance, Audit, Legal and other Risk Professionals
  • Frontline Relationship Managers, Advisers, Salespersons and Traders who make routine decisions on financing and investments on behalf of their customers and firms
  • Customer Due Diligence, Transaction Processing, Operations and Administrators
• International Law Firms, Accountants, Real Estate Agents, Trust & Corporate Services
• Commodity Trading Firms
• Exchanges, Multilateral Trading Facilities and Depositories
• Oil companies and multinationals

The course is designed to improve participants’ awareness and knowledge of sanctions risks in issuing, trading, selling or facilitating securities transactions. It focuses on the specific US & EU sanctions regimes and the practical differences and difficulties in their implementation. 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 securities and investments in a range of financial institutions.