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 Types of Economic Sanctions: • Diplomatic • Travel • Trade • Financial • **Exemptions & Licensed Activities Image: Magazine.owen.vanderbilt.edu

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 Image: Animalia-life.com

Part 2 – Challenges Available Data • Legacy Systems • Changing customer data • Limited Customer Due Diligence Information Image: henridomain.com

Part 2 – Challenges Transparency • Ownership/Controllership • “Nature and Purpose” Images: SEC.com

Part 2 – Challenges Internal Communication and Prioritisation Image: thedigitalattitude.com

Part 3 – Mitigation Customer Due Diligence Ongoing Monitoring/ Assurance Image: Medinaquality.com

Part 4 – Regulator Expectations

Part 5 – Effective Screening +

Part 5 – Effective Screening Screening Calibration Image: testingexcellence.com Image: pixabay.com

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 + + +

Part 5 – Effective Screening Beneficial Ownership European Council Council of the European Union

Part 5 – Effective Screening Automated Screening Process

Part 5 – Effective Screening Verification 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].

Part 5 – Effective Screening Verification 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.

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?

ACAMS European Chapters France Poland Netherlands Balkans Spain Baltics UK Italy Cyprus Belgium Germany Malta Ireland Nordics Learn more about ACAMS Sanctions Compliance Certificate at: http://www.acams.org/sanctions- compliance-training/