13 October 2016 Samantha J Sheen AML Director - Europe, ACAMS - - PowerPoint PPT Presentation

Sanctions: A Practical Perspective

Presentation to the ACAMS Cyprus Chapter 13 October 2016 Samantha J Sheen AML Director - Europe, ACAMS

Presentation Outline

1. Introduction 2. Current Challenges 3. Mitigation of Sanctions Compliance Risks 4. Regulatory Expectations 5. Effective Screening Practices 6. Key Takeaways

Part 1 - Introduction

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Types of Economic Sanctions:

• Diplomatic
• Travel
• Trade
• Financial
• **Exemptions &

Licensed Activities

Part 1 - Introduction

Key Characteristics

• Extraterritorial

Application (e.g. USA)

• Prohibitions and

Restrictions

• No minimum £

Thresholds

• Immediate Effect

Image: Magazine.owen.vanderbilt.edu

Part 2 – Challenges

Ever-Changing Scope

• Iran
• Cuba
• Russia/Crimea
• Myanmar
• Cote I’voire
• Disparity between

Sanction Lists

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Part 2 – Challenges

Available Data

• Legacy Systems
• Changing customer data
• Limited Customer Due Diligence Information

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Part 2 – Challenges

Transparency

• Ownership/Controllership
• “Nature and Purpose”

Images: SEC.com

Part 2 – Challenges

Internal Communication and Prioritisation

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Part 3 – Mitigation

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Customer Due Diligence Ongoing Monitoring/ Assurance

Part 4 – Regulator Expectations

Part 5 – Effective Screening

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Part 5 – Effective Screening

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Screening Calibration

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Part 5 – Effective Screening

Screening Scope

• Parties and countries relating to:

– Customers – Controllers – Beneficiaries – Counterparts – Vendors – Goods and Services – Vessels (along with shipment routes)

Part 5 – Effective Screening

When to Screen

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Part 5 – Effective Screening

European Council Council of the European Union

Beneficial Ownership

Part 5 – Effective Screening

Automated Screening Process

Part 5 – Effective Screening

AL-JABBARI, Deiman Alhasenben Ali (a.k.a. IZZAT, Dieman Abdulkadir), Adolf-Braun Street 6, Nuremberg 90429, Germany; Fuerther Street 335, Nuremberg, Germany; Nuremberg Prison, Germany; DOB 04 Jul 1965; POB Kirkuk, Iraq; nationality Iraq; Travel Document Number A0141062 (Germany) (individual) [SDGT]. Verification

Part 5 – Effective Screening

Organisation Name: SIMATEC DEVELOPMENT COMPANY Other Information: EU listing. Not UN. Assisting designated entities to violate the provisions of UN and EU sanctions on Iran. As of early 2010 Simatec was contracted by UN-designated Kalaye Electric Company (KEC) to procure Vacon inverters to power uranium enrichment centrifuges. As of mid-2012 Simatec was attempting to procure EU-controlled inverters. Verification

Part 5 – Effective Screening

Verification – Dual Use Goods

Part 5 – Effective Screening

Use of Internal Lists Exclusion Lists Inequalities or “White” Lists

Part 3 – Effective Screening

Workflows Records Management

Source: business.lovetoknow.com

Part 3 – Effective Screening

Training Effectiveness Feedback Cycle

Key Takeaways

• The sanctions landscape is constantly changing
• There continue to be challenges
• Key controls are CDD and monitoring and

assurance

• Regulatory expectations continue to increase
• Effective screening comprises of a number of

features

• To remain effective, lessons learnt should be

incorporated into training and system reviews.

Thank-you for Listening Any Questions?

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Learn more about ACAMS Sanctions Compliance Certificate at: http://www.acams.org/sanctions- compliance-training/