Sanctions Essentials: Connecting the Dots Between Sanctions and AML
Date: Thursday, February 22, 2018
Time: 12:00 PM – 01:15 PM EST
The overlap between Anti-Money Laundering (AML) and sanctions has always been undeniable. In the last 10 years, however, sanctions have emerged as a unique and separate area of compliance carrying heavy civil as well as criminal penalties for failure to comply.
Today, no compliance program is complete without taking AML and sanctions rules into consideration, and ensuring that you and your team fully understands the important convergence between these two regulatory hurdles.
This webinar will provide a practical approach to the similarities and differences between AML and Sanctions rules, as well as what a company can do to stay fully compliant with both compliance models.
Join this live SanctionsAlert.com course and learn:
- BSA/AML Examination Manual and its role in OFAC compliance program examinations
- What goes in a blocking/reject report vs. what goes in a suspicious activity report
- The overlap of sanctions and AML controls concerning activity by designated terrorist groups, militias, and other organizations
- How to ensure your sanctions and AML teams communicate appropriately with each other (and avoid common misunderstandings)
- NYDFS Part 504 and how AML concepts are increasingly being applied to sanctions compliance
- Tools at the disposal of FinCEN, including Section 311 of the USA Patriot Act, which contains a “Trade Sanctions” provision in section 221 of Title II “Enhanced Surveillance Procedures”
- The intersection between FinCEN’s CDD rule and OFAC’s 50% rule
- How Section 206 of the International Emergency Economic Powers Act (Title 50, US Code Sec. 1705) is among the 200 “Specified unlawful activities” (SUAs) that can serve as a predicate to a U.S. AML prosecution by DOJ
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Certificate of Attendance
If you participate in the live webinar, you will receive a Certificate of Attendance, which you can use to show you meet your government-required training duties.
Global Head of Sanctions, Interdiction & Anti-Corruption
Tyler’s responsibilities with Western Union include overseeing the company’s Office of Foreign Assets Control and other government sanctions compliance programs, as well as the company’s proprietary list-screening operations. Tyler joined Western Union in June 2014 after working for seven years at the United States Department of the Treasury in Washington, DC. During his time with the Treasury Department, Tyler served as OFAC’s Assistant Chief Counsel for Designations and Enforcement and as Acting Director for Enforcement. While at the Treasury Department, Tyler’s responsibilities included developing and implementing policies related to OFAC enforcement and designation matters, drafting sanctions Executive Orders and regulations, and advising on large interagency enforcement investigations involving major financial institutions. Tyler also served as the primary point of contact for counterparts at the Department of Justice, the Department of State and the White House National Security Staff. Prior to joining OFAC, Tyler practiced law at Holland & Hart in Denver, CO in its Export Controls and Trade Sanctions practice group. Tyler received his JD in 2000 from the University of Colorado School of Law, Boulder, and his Bachelor of Arts in 1995 from the University of Vermont, Burlington.
Crowell & Moring LLP
Carlton is a partner in Crowell & Moring’s Washington, D.C. office and a member of the firm’s International Trade and White Collar & Regulatory Enforcement groups. He provides strategic advice to clients on U.S. economic sanctions, Bank Secrecy Act and anti-money laundering (AML) laws and regulations, export controls, and anti-corruption/anti-bribery laws and regulations. Carlton is the former chief counsel at FinCEN (the Financial Crimes Enforcement Network), the U.S. AML regulator responsible for administering the Bank Secrecy Act.
Before joining FinCEN, Carlton previously served as the assistant director for transnational threats with the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC), where he directed targeting and investigations for more than 15 U.S. economic sanction programs, including those related to Iran and North Korea. Carlton also served as legal counsel to OFAC on counter terrorism sanctions. Previously, he was appointed by the United Nations Secretary-General to advise the UN Security Council on international sanctions against Al-Qaida and the Taliban and to lead member state visits to assess compliance. Carlton also previously served as a trial attorney at the U.S. Department of Justice, where his practice included representing OFAC on sanctions issues.
Based on his years of experience with OFAC and FinCEN, Carlton offers valuable insights on the approaches of these agencies that will assist corporate clients to more effectively respond to government investigations, as well as update their corporate compliance programs in general.
Bank of America
“Great knowledge from the presenters and the content was relevant”
— José R. Fernandez, Bank of America – Charlotte, NC, USA
“Great coverage of information”
— Cathy Swindell-Smith, Wells Fargo – Charlotte, NC, USA
Axa Equitable Life Insurance Company
“It was very informative. The speakers were clear and the information was disseminated in a clear, concise manner.”
— Nicolette Douglas, Axa Equitable Life Insurance Company – New York, NY, USA
“The content was excellent and easy to understand. The presenters did a great job!”
— Susan Wilson, RBC – Toronto, Canada
“Both speakers were exceptionally knowledgeable and provided practical information regarding the sanctions changes”
— Adam Hermes, Comerico Bank – Livonia, USA