Due Diligence: Know Your Customer and Business Partner to Unveil Sanctioned Parties and Hidden Beneficial Owners


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On Demand Webinar

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Overview:

During this practical webinar, our panelists will share best practices on how they have approached customer due diligence for sanctions compliance purposes and where to focus limited resources.

Using audience polls, this interactive session also gives attendees the unique opportunity to benchmark their CDD compliance programs against their peers in the industry.

CDD for sanctions purposes goes beyond list screening and know your customer (KYC) during on boarding or periodic reviews and extends into CDD related to pre-transaction checks. The session will provide insights into the essential elements of a strong CDD compliance program focusing on sanctions compliance, and will explore tailored strategies to address these risks in a OFAC/sanctions compliance program.

An example of the scenario to be discussed include: You are doing due diligence on a Russian party, with financial interests worldwide. You are screening him as an individual, and he turns out to be listed. Now, you’re also responsible for screening for evidence whether he might be Ultimate Beneficial Owner (UBO) holding at least 50 % ownership in other corporate customers or business partners? How to leverage the information in your CDD/KYC data for sanctions screening purposes to capture listed UBOs?

What you will learn:

  • What regulators and auditors expect to see in your CDD program to detect embargoed countries, denied parties and prohibited end-users;
  • Practical guidance on applying OFAC’s 50% rule, and FINCEN’s customer due diligence rule;
  • Use of OFAC enforcement guidelines, FFIEC BSA/AML Examination Manual in formulating your CDD procedures;
  • How to perform Enhanced Due Diligence on clients with high risk for sanctions;
  • How to perform on-going Know Your Client updates while sanctions are so dynamic;
  • Most common mistakes when conducting CDD for sanctions compliance purposes, and how to develop more effective CDD policies and controls.
Iran

Date Aired: 

June 8, 2017

Duration: 

75 minutes

Speakers

Salvatore Scotto
Brian Ferro

Sanctions Compliance in the Non-Bank Financial Sector


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On Demand Webinar

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Overview:

Much attention has been focused on the banking sector in recent years with multi-million dollar penalties imposed by OFAC and other government agencies for sanctions program violations. However, other financial service sectors, such as money services businesses, insurers and the credit card industry, are now subject to similar attention and, consequently, and has forced them to enhance greatly their OFAC/sanctions compliance capabilities and procedures.

But challenges remain. The rapidly-evolving sanctions environment has added an additional layer of complexity to compliance efforts within those industries already attempting to make up ground.

The obligation to comply with sanctions extends to a range of non-bank financial products and activities, but sanctions implementation can be costly and complex and it can be difficult to determine whether compliance policies and procedures meet the challenges. Instances of OFAC/sanctions program deficiency or noncompliance may result in investigations, and look-backs potentially culminating in monetary fines or government enforcement actions.

Are you really ready for an era of increased accountability in OFAC sanctions compliance?

What you will learn at this SanctionsAlert.com webinar:

  • Lessons from OFAC enforcement cases against non-banks, including how US extraterritorial sanctions can target non-US institutions
  • How regulators are equipped to deal non-traditional methods of payment and remittance platforms?
  • How to achieve robust governance, oversight, and accountability at senior levels
  • New approaches to CDD/KYC in card and remittance frameworks
  • How to implement evolving OFAC/sanctions compliance programs with minimum risk to commercial activities and partners?

During this live course, we’ll use audience polling, providing you with vital industry insights, such as:

  • In your opinion, do companies that adhere to strict OFAC standards sooner than their competitors will have an early advantage?
  • Does your company conduct SDN/OFAC screening in real time or batch-mode?
  • Does your company have a risk assessment for OFAC/sanctions compliance?
  • In your company, how many other “hats” does the person responsible for OFAC compliance wear?
Iran

Date Aired: 

May 11, 2017

Duration: 

75 minutes

Speakers

Tyler
Howard R. Fields

Critical Update on Iran Sanctions: Navigating an Increasingly Complex Regime


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On Demand Webinar

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Overview:

In February, the U.S. sanctions imposed new sanctions on Iran, targeting dozens of companies and individuals, including Chinese firms suspected of supplying parts used in Iran’s missile development program. Iran then retaliated with its own blacklist of American nationals and companies it said gave support to terrorists.

On March 23, 2017, U.S. Congress introduced two new bills aimed at increasing non-nuclear sanctions against Iran. The bill, if passed, is very broad, and would authorize new “secondary sanctions” which present compliance headaches for many, even those companies with little nexus to the US.

New guidance from the UK, coming into force this month, says that any company with a UK “nexus” and companies that do business abroad or with foreign nationals will be at risk for heavy penalties for sanctions violations. This is a significant development and is likely to bring about an increase in the number of financial sanctions enforcement actions in the UK.

Can you keep up? How will these new developments affect the JCPOA and the sanctions that were eased earlier? Which sanctions are still in place?

What are practical considerations when dealing with financial institutions that are wary to process transactions involving Iran?

This live, interactive SanctionsAlert.com webinar will cover practical issues arising from the latest developments related to sanctions regime for Iran.

What you will learn at this SanctionsAlert.com webinar:

  • Which sanctions have been lifted and which are remaining on financial services, oil and gas, energy and import/export, and more;
  • Differences in EU and U.S. sanctions relief;
  • The scope of permissible activities with Iran under U.S. and EU legal requirements;
  • Strategies for minimizing risks as the US administration weighs the future of JCPOA;
  • Practical due diligence issues: e.g. how do you decide if there is an IRGC connection?
  • Are companies able to effectively use OFAC’s General License H?
Iran

Date Aired: 

April 6, 2016

Duration: 

75 minutes

Compliance Processes and Procedures That May Help Reduce Criminal and Regulatory Sanctions Problems


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On Demand Webinar

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Overview:

Treasury’s Office of Foreign Assets Control (OFAC), Commerce Department Bureau of Industry and Security (BIS), and law enforcement have turned up the heat, forcing financial institutions and corporations to have compelling evidence of good sanctions governance, sound sanctions-related CDD controls, and robust sanctions screening documentation.

The newly-promulgated Department of Justice Guidance establishes the criteria for assessing the degree of credit a corporate entity will receive for voluntary self-disclosure of willful violations of export control and sanctions laws. OFAC enforcement actions, and “Enforcement Guidelines” also provide vital information of what the government expects and what can get you into trouble.

What you will learn:

  • The long arms of the U.S. Justice Department, Treasury, Commerce and State Department and how they may bring sanctions troubles to businesses,
  • The October 2016 DOJ Voluntary Disclosure Guidance and how it signals an expanded role in export control & sanctions investigations
  • Use of OFAC Enforcement Guidelines in formulating your customer due diligence procedures for sanctions compliance purposes
  • How to get credit for responding properly to government inquiries and bring institutional value back
Iran

Date Aired: 

December 1,  2016

Duration: 

75 minutes

OFAC’s Sibling – The Commerce Department’s Bureau of Industry and Security and How Its Regulatory and Criminal Powers Are Applied


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On Demand Webinar

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Overview:

This live course will provide crucial information on the role of this little known agency and how it shares licensing jurisdiction with Treasury’s OFAC and can impose hefty penalties for non-compliance with export controls and sanctions.

Alongside Theodore Curtin, Senior Policy Analyst and Licensing Officer at BIS, Peter Jeydel, the Vice Chair of the American Bar Association’s Export Controls and Economic Sanctions Committee of the International Law Section, and Counsel at Steptoe, will discuss the key challenges related to export violations punished by BIS with lessons from real cases, and how to comply with BIS regulations in global trade compliance programs, including related to the Cuban program.

This course brings an expert attorney and government official from BIS itself, both involved in arms controls and export compliance, thus allowing you to develop your knowledge of global export and sanctions controls.

What you will learn:

  • The role and powers of the U.S. Commerce Department’s Bureau of Industry and Security (BIS)
  • How the criminal enforcement powers of the BIS Office of Export Enforcement work and are applied,
  • How the new BIS Enforcement Guidelines will change enforcement practice and will look more like OFAC
  • Challenges and best practices when OFAC economic sanctions and BIS strategic export controls intersect
  • Navigating the Commerce Department BIS rules on exporting “Dual-Use” items
Iran

Date Aired: 

March 9, 2016

Duration: 

75 minutes

Speakers

Peter Jeydel