Advanced Sanctions Risks

Session 1: Introduction

• The Global Sanctions Framework

• Applying Sanctions

Session 2: US Sanctions on Russia

• Countering American Adversaries Through Sanctions Act (CAATSA) SSIs: Financial institutions

• Energy companies

• Defence and Intelligence Agencies

• Overseas ownership by energy companies

Facilitation and secondary sanctions

Investment in state-owned enterprises

Restrictions on Crimea

Crimea sanctions:

• Technology and the Defence Sector

• Russian sovereign debt

Russian Harmful Foreign Activities Sanctions:

• Major Russian Banks

• Oligarchs and Proxies

• Imports & Exports

• Investments

• Definition of investment

• Sovereign Debt

• Energy

• Ministry of Finance, Sovereign Wealth Fund & Central Bank

• Correspondent & Payable Through Accounts (PTAs)

Prohibitions on services

Exercise: Company A

Case Study: Sibneft Privatisation

Case Study: The Russian Laundromat

Session 3: EU Sanctions on Russia

• Prohibitions & Restrictions: Finance

• Defence

• Dual-Use Goods

• Energy

• Economic Cooperation

Asset Freezes and Travel Bans on Individuals

Crimea Restrictions:

• Business

• Investment

SWIFT Ban on Major Banks

Prohibitions and Restrictions:

• Individual Bans & Asset Freezes

• EU Capital & Financial Markets

• Financial Institutions

• Defence & Dual Use Goods

• Major Industry Sectors

• Investments

• Investment Services & Products

• State-Owned Enterprises

• Public Investments

• Nord Stream 2

• Brokering, Financing or Guaranteeing Restrictions

Advanced Sanctions Training Exercise: Sanctions Product Evaluation

Session 4: UK Sanctions on Russia, Pre-Ukraine Invasion

• The Russia (Sanctions) (EU Exit) Regulations 2019

• Differences with the EU Regime

• Asset Freezes & Travel Banks on Individuals

• Restrictions on Crimea

• Prohibitions and restrictions: Banking and financial markets

• Major Russian Banks

• Major Russian Companies

• Public Investments

• State-Owned Enterprises

• Dual-use goods and technology

• Exports and import bans

Other countries' sanctions on Russia

Session 5: Sanctions on Belarus

• Travel Bans and asset freezes on individuals

• Prohibitions and restrictions: Imports and exports

• Defence

• Major sectors of the economy

• Investments

• State-owned entities

• SWIFT

• Banking and financial markets

Session 6: Sanctions on Iran, North Korea, Syria & Myanmar

• Iran: Non-proliferation

• Defence

• Travel bans and asset freezes

• Energy and energy investments

• Collapse of the JCPOA

• Major sectors of the economy

• Iranian Security Services

North Korea:

• CAATSA North Korea

• UNSC Sanctions

• Non-Proliferation

• Defence and military

Syria:

• Energy and energy investments

• Travel bans and asset freezes

Myanmar:

• Restrictions and prohibitions

• Regime focus

• Implications for business

Session 7: Sanctions on China, Venezuela & Cuba

• China: CMICs

• SDN vs Non-SDN

• Subsidiaries

• Investment & Advisory Services

• Future Designations

Venezuela Sanctions Targets:

• The Regime

• PdVSA

US Embargo on Cuba

Session 8: Beyond Sanctions – Trade & Human Rights

• Sanctions risk online training examines trade finance and sanctions risks

• US Export Administration Regulations (EAR)

• Magnitsky Act & Global Magnitsky Act

• EU & UK Human Rights Regulations

Session 9: Assessing Sanctions Risk Exposure s

• The Risk-Based Approach

• Who is subject to US sanctions?

• Direct and indirect sanctions exposures

• Assessing Sanctions Risk Exposures

• Affiliate Risk Management

Case Study: Singapore Telecom

Case Study: The UNDP in North Korea

Case Study: Standard Chartered

Exercise: US Nexus

Exercise: Direct & Indirect Exposure

Session 10: Key Topics in Sanctions Evasion

• Huawei and ZTE

• Siemens in Russia

• Russian Sanctions Evasion

• Iran and Turkey

• Gold and cryptocurrencies

• Non-Bank Financial Institutions (NBFIs)

• Integration of money laundering and sanctions evasion techniques

• North Korea

Case Study: Turkey and Iran’s Gold Trades

Case Study: Russian / Gazprom Offshore Financing

Case Study: Cryptocurrency Expert in North Korea

Session 11: Sanctions CDD

• The Sanctions CDD Framework

• Is there a difference vis-à-vis regular CDD? ID & V

• KYC

• ODD

• EDD

Beneficial Ownership

Trigger Events

Case Study: 650 Fifth Avenue, New York

Case Study: Ongoing Due Diligence

Exercise: Hidden Ownership

Session 12: Sanctions Screening Training

• Who do we screen?

• When do we screen?

• Payment and transaction screening

• Sanctions Data Framework

• Patriot Act

• Payment transparency

• Fines and penalties

• Sanctions narrative and the customer ecosystem

• Importance of frontline staff

Case Study: BNP Paribas

Case Study: Putin & The Proxies

Session 13: Sanctions Risk Management (OFAC Sanctions Training)

• OFAC Management Framework

• Sanctions Compliance Programme – key points

• Root causes of OFAC SCP breakdowns

Final Sanctions Training Case Study: Westpac’s Epic Fail

Training Objectives

Redcliffe Training's Advanced Sanctions Risk course will assist you in developing:

• An understanding of the major US, EU and UK sanctions regimes and how they impact financial institutions. Especially those in Russia, Iran, North Korea, Syria, Cuba, Belarus and China.

• A deeper understanding of the nature of sanctions regimes and the nature of sanctions risk exposures.

• A deeper understanding of how sanctions risk exposures arise. How they permeate business activities in financial institutions and their business relationships.

• Awareness of key sanctions risk management topics and issues you must address within financial institutions.

• The major challenges presented by sanction evasion techniques.

• Best practices in deterring and detecting sanctions risk violations.

• Greater awareness of the roles and responsibilities of managing sanctions risks.

Training Course Summary

Redcliffe Training's sanctions training courses ensure you gain a comprehensive understanding of sanctions risks across both financial and non-financial institutions.

This course provides an in-depth exploration of critical topics, such as the identification and assessment of sanctions risks, the intricacies of the evolving regulatory landscape, and the vital role that robust compliance frameworks play in mitigating these risks.

Participants will gain a deep understanding of how to navigate the nuances of international sanctions regimes. This includes those imposed by authorities such as the United Nations, European Union, and the U.S. government.

Tailored for professionals at all levels, this comprehensive course blends in-depth theoretical knowledge with practical insights, enabling delegates to understand the complexities of sanctions and apply best practices in real-world scenarios. Financial sanctions training provides significant value to sanctions specialists, financial crime professionals, risk managers, and executives responsible for overseeing their organisation’s sanctions risk exposures, helping them strengthen compliance frameworks and mitigate potential risks.

This course is available in virtual classrooms or can be delivered in-house.